US: Court of Appeals determines tax authorities cannot reallocate income beyond a taxpayer’s legal entitlement
The IRS sought to reallocate an additional USD 23.7 million in royalties to 3M under the arm’s-length standard, despite the company’s Brazilian subsidiary being legally limited to paying only USD 5.1 million. The US Court of Appeals for the
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France approves Amount B simplified transfer pricing method for transactions with developing countries
France will restrict the use of the OECD's Amount B transfer pricing method to transactions with developing nations that have adopted the method and have a bilateral tax treaty with France, excluding non-qualifying jurisdictions. France
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Tanzania enacts 2025-26 budget measures, includes new transfer pricing penalty
The measures will apply from 1 July 2025, unless otherwise specified. Tanzania's Finance Act 2025 was enacted on 30 June 2025, implementing tax measures from the 2025-26 Budget Speech with some adjustments to the initially announced
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Australia: Administrative Review Tribunal rules in favour of Alcoa against ATO in key transfer pricing ruling
This case focused on a major transfer pricing issue, where ATO claimed Alcoa underpriced its alumina sales to Aluminium Bahrain B.S.C. (Alba) from 1993 to 2009, causing a tax shortfall of over AUD 213 million. Australia’s Administrative Review
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Poland: Council of Ministers approve bill to ease group taxation, transfer pricing rules
Poland's Council of Ministers approved a proposal to simplify group taxation and transfer pricing regulations on 21 May 2025. Poland’s Council of Ministers approved a proposal on 21 May 2025 to streamline the country’s group taxation and
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UN Tax Committee: Transfer Pricing Subcommittee Discusses Future Guidance
On 26 March 2025 the UN Tax Committee discussed their transfer pricing work. Since the previous session of the Committee, the Subcommittee on Transfer Pricing has gathered feedback from members on possible future workstreams that could be pursued by
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Serbia adopts rulebook on arm’s length interest rates for 2025
Serbia’s Ministry of Finance has issued the Rulebook on arm’s length interest rates for 2025, which was published in the Official Gazette of Serbia No. 17/2025 on 28 February 2025. The rulebook establishes specific interest rates for both
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Luxembourg issues new guidelines on interest rates for debit current accounts
The Luxembourg Administration of Direct Tax has released Circular L.I.R. no. 164/1 on 29 January 2025, detailing updated rules for determining interest rates on debit current accounts held by associates or shareholders of corporate taxpayers. The
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Australia: ATO updates guidance on transfer pricing for inbound-related private group funding
The Australian Taxation Office (ATO) has released new guidance on transfer pricing for inbound related party funding within private groups that receive funding from an overseas related party or associate for property and construction on 15 January
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Bangladesh: NBR to conduct first transfer pricing audit to tackle tax evasion
Bangladesh tax authority National Board of Revenue (NBR) announced that it will conduct its first transfer pricing audit of multinational companies (MNCs) operating in the country. Bangladesh first introduced transfer pricing provisions in the
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Argentina issues transfer pricing rules for SPV transactions under large investment incentive regime
Under the new rules, SPVs must annually file transfer pricing analyses with the ARCA for both local and international transactions, including those in low- or no-tax jurisdictions, and may engage in Contribution and Cost Sharing
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Chile updates tax compliance law, introduces changes to GAAR, transfer pricing, and CFC
Chile's Internal Revenue Service (SII) has announced that the Law on Compliance with Tax Obligations (Law No. 21.713) has been published in the Official Gazette on 24 October 2024. General and Special Anti-Avoidance Rules changes The General
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UN Tax Committee: Issues in Extractive Industries Taxation
On 15 October 2024 the UN Tax Committee discussed developments in their work on extractive industries taxation. The work of the relevant subcommittee has focused on the energy transition; the valuation of mining products for tax purposes; and tax
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Cyprus publishes FAQs on new transfer pricing rules
The tax authority has published additional frequently asked questions (FAQs) numbered 25 – 43 to provide clarity on specific provisions of the new transfer pricing rules in Cyprus. Notably, FAQ 25 clarifies that taxpayers do not need to
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OECD publishes model agreement for Pillar One Amount B
The Organisation for Economic Co-operation and Development (OECD) announced the release of a Model Competent Authority Agreement (MCAA) concerning Amount B of Pillar One, a part of the OECD/G20 Inclusive Framework on BEPS yesterday, 26 September
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OECD: Report on Simplified Peer Review of Egypt under BEPS Action 14
On 16 September 2024 the OECD published the simplified peer review report on Egypt under Action 14 of the project on base erosion and profit shifting (BEPS). The report sets out the results of Stage 1 of the simplified peer review of the
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OECD: Report on Simplified Peer Review of Nigeria under BEPS Action 14
On 16 September 2024 the OECD published the simplified peer review report on Nigeria under Action 14 of the project on base erosion and profit shifting (BEPS). The report sets out the results of Stage 1 of the simplified peer review of the
See MoreOECD: Report to the July Meeting of G20 Finance Ministers
On 25 July 2024 the OECD published the report prepared for the meeting of G20 Finance Ministers and Central Bank Governors held in Brazil from 25 to 26 July 2024. The report notes some recent developments in important areas of international tax
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