Czech Republic: Supreme Administrative Court issues ruling on limits of transfer pricing rules
The Supreme Administrative Court (SAC) of the Czech Republic has issued a ruling on 12 November 2025, concerning a tax dispute involving the company Astemo Czech, s. r. o., and the Appellate Financial Directorate. The ruling includes informal
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Poland: Senate approves bill to ease corporate tax rules
The legislation repeals the requirement for large corporate income taxpayers to publish a report on their executed tax strategy. Poland’s Senate passed two tax legislation amendments without changes on 17 July 2025. Corporate Income Tax
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Denmark: Parliament approves changes to Pillar Two minimum tax, Pillar One Amount B, related measures
The Parliament approved Bill L 194A on 3 June 2025. Denmark’s parliament has approved Bill L 194A, amending the Minimum Taxation Act, Corporate Tax Act, and other laws on 3 June 2025. Minimum Taxation Act and Corporate Tax Act The
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Algeria extends 2024 corporate income tax filing deadline
Algeria’s National Tax Administration (NTA) announced an extended deadline for corporate income tax (CIT) filing on 14 April 2025. The new deadline is set for 31 May 2025. However, since 31 May falls on a holiday, the revised deadline is set for 1
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India enacts Finance Act 2025, offers support for targeted sectors of the economy
India's Central Board of Direct Taxes (CBDT) has released the Finance Act 2025 on 29 March 2025. The Act was officially enacted on 29 March 2025, following the President's assent, implementing the provisions outlined in the 2025–2026
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Canada updates rules for paying non-residents for services
The Canada Revenue Agency (CRA) released an updated guide – T4A-NR – Payments to Non-Residents for Services Provided in Canada – for those who make payments to non-resident individuals, partnerships, or corporations for services rendered in
See MoreKenya: Tax Appeal Tribunal issues rule on a case of management fees
On 1 April 2021, the Kenyan Tax Appeals Tribunal (TAT) ruled on tax disputes between McKinsey and Company Inc. Africa Limited (McKinsey / the Appellant) and the Kenya Revenue Authority (KRA / the respondent) in relation to withholding tax (WHT) on
See MoreSouth Africa: Court makes a decision regarding TP methods
On 7 January 2021, in the case of: ABC (Pty) Ltd v. Commissioner (IT 14305) ZATC 1, the South African Court upheld a transfer pricing adjustment for a taxpayer that failed to have transfer pricing documentation to support the arm’s
See MoreOECD: Forum on Tax Administration Agrees Action on Administrative Challenges
On 8 December 2020 representatives of the members of the OECD’s Forum on Tax Administration (FTA) agreed on an agenda for 2021 focusing on tax certainty and digital enhancement of tax administration. The FTA is a global forum on tax
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UK: Updated Statistics on Transfer Pricing and Diverted Profits Tax
On 12 November 2020 HMRC published updated statistics relating to transfer pricing and the diverted profits tax for 2019/20 (the year to 31 March 2020). In 2019/20 a total of 125 transfer pricing enquiries were settled, with an average
See MoreECJ: Ruling on Transfer Pricing Treatment of Bank Transfers Between Branch and Parent
On 8 October 2020 the European Court of Justice (ECJ) ruled on Romania’s transfer pricing rules in relation to bank transfers from a branch to a head office that is located in another EU Member State. Impresa Pizzarotti concluded two loan
See MoreCzech Republic: Supreme Court makes a decision regarding transfer pricing issues
Recently, the Supreme Administrative Court has issued a landmark decision for companies that have incentives to invest in older systems. The court confirmed that failure to meet the condition not to increase the tax base for calculating tax relief
See MoreDenmark: National tax court clarifies TP documentation rules for intergroup companies
On 24 September 2020, the Danish Tax Administration published a Decision No. SKM2020.387.LSR, clarifying the transfer pricing documentation requirements for a change of business structure within a group company. The case concerns a Danish
See MoreCanada: The Tax Court makes a decision in a case regarding transfer pricing dispute
On 27 August 2020, the Tax Court of Canada made a decision in a case, Canada vs AgraCity Ltd. and Saskatchewan Ltd., in favor of Candian company AgraCity Ltd. and related company, Saskatchewan Ltd. The AgraCity Canada had entered into a Services
See MoreOECD: Transfer Pricing Guidance on Financial Transactions
On 11 February 2020 the OECD released a report entitled Transfer Pricing Guidance on Financial Transactions: Inclusive Framework on BEPS: Actions 4, 8-10. The OECD reports on base erosion and profit shifting (BEPS) issued in 2015 requested
See MoreUK: Statistics on Transfer Pricing and Diverted Profits Tax
On 27 January 2020 HMRC published statistics relating to transfer pricing and the diverted profits tax. HMRC had 441 full time equivalent staff working on international tax issues involving multinational groups in 2018/19, including transfer
See MoreDenmark: National Tax Court publishes a decision on the scope of controlled transaction
On 3 January 2020, the National Tax Court published a decision regarding a Case dealing with controlled transactions that "transactions" also include a provision where there is a capital reduction in a company, which is carried out by a reduction
See MoreUS: Court of Appeals Withdraws Opinion in Altera case
On 8 August 2018 the US Court of Appeals (Ninth Circuit) announced that it was withdrawing its opinion of 24 July 2018 in the Altera Corp case, concerning the treatment of stock based compensation by related parties in a cost sharing arrangement
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