UK: HMRC updates CbC reporting guidance
UK’s His Majesty's Revenue and Customs (HMRC) updated its country-by-country reporting (CbCR) guidance on 17 March 2026, clarifying which entities must report, how to register and submit reports, and the process for agents seeking
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Vietnam: MoF drafting new transfer pricing, taxpayer obligations, CbC reporting rules
The Vietnamese Ministry of Finance (MoF) is preparing a draft Decree on tax administration for related-party transactions of enterprises with affiliated relationships, in line with the Law on Tax Administration No. 108/2025/QH15. The new
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UN Tax Committee Discusses Extractive Industries Taxation
The 32nd session of the UN Committee of Experts on International Cooperation in Tax Matters commenced on 23 March 2026. The Committee discussed the continuing work on aspects of taxation in the extractive industries. The relevant subcommittee
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OECD updates signatories list for MCAA-CbC
The Organisation for Economic Cooperation and Development (OECD) released an updated list of signatories, along with their signing dates, for the Multilateral Competent Authority Agreement (MCAA) on the Exchange of Country-by-Country (CbC) Reports
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Korea (Rep.) introduces transfer pricing reforms, Pillar Two rollout
Korea (Rep.) has published Presidential Decree No. 36128, partially amending the enforcement Decree of the International Tax Adjustment Act, in the Official Gazette on 27 February 2026. The Decree introduces sweeping updates to its international tax
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UN: 32nd Session of Committee of Experts on Tax Cooperation
The 32nd session of the UN Committee of Experts on International Cooperation in Tax Matters is to be held from 23 to 26 March 2026. A provisional agenda has been issued, which includes the following topics: UN Model Tax Convention Work on the
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Iceland: Court of Appeals rule taxpayers must prove arm’s length pricing in related-party deals
The Icelandic Court of Appeals (Landsréttur) upheld the ruling of the District Court of Reykjavík in Iceland’s first transfer pricing case (No. 213/2025) on 19 February 2026. The court confirmed that taxpayers must prove that related-party
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Australia: ATO releases public country-by-country reporting compliance guidance
The Australian Taxation Office (ATO) has released instructions to complete the public country-by-country report on 3 March 2026. The instructions include: Public CBC report overview Overview of Public CBC report instructions and publishing
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Georgia introduces reporting obligations for international controlled transactions exceeding GEL 500,000
Georgia has issued Order No. 52 of 24 February 2026, in the Official Gazette, establishing a new annual obligation to report information on international controlled transactions. The order introduces a mandatory reporting requirement for entities
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Ukraine: MoF consults transfer pricing reform bill
Ukraine’s Ministry of Finance (MoF) opened a public consultation on a draft law titled “On Amendments to the Tax Code of Ukraine Regarding Further Improvement of Transfer Pricing Rules” on 24 February 2026. The draft was prepared with the
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UN: Discussion of Protocol on Dispute Prevention and Resolution
In February 2026 the intergovernmental negotiating committee (INC) continued discussions on the UN Framework Convention on International Tax Cooperation, looking at the early Protocol on tax dispute resolution. Dispute resolution
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Poland: Court rules deferred tax regime doesn’t exempt companies from transfer pricing rules
Poland's Supreme Administrative Court has ruled that companies using the deferred corporate income tax regime must comply with transfer pricing rules, including Local File documentation requirements. This ruling details a judgment from the
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OECD releases Amount B Pillar One guidance, pricing automation tool
The OECD published new materials on 17 February 2026 to assist with the rollout of Amount B under Pillar One, which provides a simplified transfer pricing framework for baseline marketing and distribution activities. The release includes updated
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OECD introduces manual on mutual agreement procedures via technical webinar
The OECD hosted a technical webinar on the revised Manual on Effective Mutual Agreement Procedures (MEMAP) on 10 February 2026, in support of the broader focus of the BEPS Inclusive Framework and the Forum on Tax Administration (FTA) on improving
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Colombia: DIAN highlights 2025 transfer pricing adjustment requirements
Colombia’s tax authority (DIAN) has issued a notification, on 6 February 2026, for large taxpayers subject to the transfer pricing regime to make any required transfer pricing adjustments when filing their 2025 fiscal year income tax return. As
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OECD updates manual on effective mutual agreement procedures
The OECD has released updated guidance by the Inclusive Framework on BEPS on 2 February 2026, aimed at improving tax certainty by helping tax administrations and taxpayers resolve cross-border tax treaty disputes in an efficient, effective and
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US: IRS releases US–Spain competent authority agreement on arbitration
The US Internal Revenue Service (IRS) has released Internal Revenue Bulletin No. 2026-6 on 2 February 2026. The bulletin includes Announcement 2026-3, which sets out the Competent Authority Arrangement agreed between the US and Spain to implement
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France simplifies EU public CbC reporting rules
France adopted new rules on 28 December 2025 to streamline compliance with the EU public CbC reporting directive (Directive (EU) 2021/2101), fully aligning national law with EU requirements and implementing the multiple reporting exemption. The
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