India: Tax Authority appeals high court ruling on treaty limits to dividend tax
The Indian Income Tax Department filed a special leave petition before the Supreme Court on 30 January 2026, challenging a Bombay High Court ruling that held Dividend Distribution Tax (DDT) could be limited by applicable tax treaties. The appeal
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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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Latvia introduces controlled transactions report to streamline transfer pricing compliance
Latvia has significantly reshaped its transfer pricing compliance framework from 1 January 2026, following amendments to the Law “On Taxes and Fees” adopted at the end of 2025. The changes are designed to modernise reporting requirements, reduce
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Poland proposes new digital services tax legislation
Poland’s Ministry of Digital Affairs announced on 27 January 2026 that it has submitted draft legislation to introduce a Digital Services Tax (DST). First discussed in August 2025, the draft proposes a DST of up to 3% on a broad range of
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China releases 16th annual APA report (2024), highlighting strong growth, efficiency
China’s State Taxation Administration (STA) published its 16th Annual Advance Pricing Agreement (APA) Report on 25 November 2025, providing a comprehensive overview of the country’s APA programme and its development between 2005 and 2024. The
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Belgium updates Local File form, clarifies use of ‘Termination of CBC notification obligation’
Belgium’s Federal Public Service (SPF) Finance has released a BEPS13 News update detailing the new Local File form issued in December 2025 and providing guidance on using the “Termination of notification obligation” for CbC filings
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OECD publishes transfer pricing profiles for eight countries
The OECD has published the revised transfer pricing country profiles, including profiles for Bosnia and Herzegovina, Brazil, Costa Rica, Croatia, Greece, Iceland, Korea (Rep.), and Norway on 22 January 2026. These profiles focus on countries'
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Switzerland updates CbC reporting list
Switzerland has updated its list of jurisdictions for the automatic exchange of Country-by-Country (CbC) reports under the Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (CbC MCAA). Decision No. RO
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UK: HMRC updates guidance on transfer pricing, PE rules, diverted profits tax
The UK tax authority, His Majesty's Revenue and Customs (HMRC) has updated its International Manual, providing revised guidance on key taxation areas affecting multinational companies. The updates, published on 16 January 2026, include the
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Luxembourg: Government Council updates CbC reporting jurisdiction list
Luxembourg’s Government Council chaired by Prime Minister Luc Frieden, met on 16 January 2026 to review international, European, economic, social and financial policy matters and to adopt a series of legislative and regulatory measures. Among
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OECD: Presentation of the Side by Side Rules
On 13 January 2026 the OECD held a webinar to discuss the side-by-side arrangements issued earlier in the month. The side-by-side (SbS) arrangement would be available where a country’s tax regime has similar policy objectives and scope to the
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Montenegro ratifies BEPS Multilateral Instrument, covering 40 tax treaties
Montenegro has taken a further step toward implementing the OECD/G20 Base Erosion and Profit Shifting (BEPS) Multilateral Instrument (MLI), with its provisional list of reservations and notifications indicating that 40 of its tax treaties will be
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Denmark issues consolidated rules on tax-free business conversions
The Danish Official Gazette published Executive Order No. 24/2026 on 13 January, proclaiming the consolidated text of the Act on Tax-Free Business Conversion. The consolidation incorporates amendments introduced by Act No. 1576 of 27 December 2019,
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Hungary updates transfer pricing documentation framework
Hungary has adopted revised transfer pricing documentation rules under Decree No. 45/2025, published in the Official Gazette on 23 December 2025. The revised rules will require taxpayers to reassess their compliance approach ahead of the 2026
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Argentina raises statutory limit for tax evasion cases
Argentina has increased the thresholds for tax evasion and aligned the statute of limitations with civil and commercial regulations under Law 27,799, which was published in the Official Gazette on 2 January 2026. Law 27,799 introduces a
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Colombia: DIAN raises tax value unit for 2026
The Colombian Tax and Customs National Authority (DIAN) issued Resolution No. 000238 on 15 December 2025, setting the Tax Value Unit (Unidad de Valor Tributario – UVT) for 2026 at COP 52,374. This is an increase from COP 49,799 in 2025. The UVT
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