Kuwait approves accession to BEPS multilateral convention
Kuwait has published Decree-Law No. 62 of 2026 in the Official Gazette on 7 June 2026, approving the country's accession to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting
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India: CBDT rolls out 2026 income tax rules with expanded transfer pricing framework
India’s Central Board of Direct Taxes (CBDT) issued Notification No. 22/2026 on 20 March 2026 under the Income Tax Act, 2025, introducing the Income Tax Rules, 2026. The rules provide a comprehensive framework for income tax administration,
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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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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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Argentina implements the BEPS MLI
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) entered into force for Argentina on 1 January 2026. Argentina signed the convention on 7 June 2017 and deposited its final MLI Position on 29 September
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Korea (Rep.) issues 2025 MAP guidelines for international tax disputes
Korea (Rep.)’s National Tax Service (NTS) on 18 December 2025 published online the 2025 Guidelines for Requesting Mutual Agreement Procedure (MAP) Assistance, providing a comprehensive framework for resolving international tax disputes with treaty
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Finland updates BEPS MLI stance on Brazil tax treaty, including correctionsÂ
Finland submitted an updated consolidated position for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), as noted by the OECD on 11 December 2025. This update includes two specific corrections regarding
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Georgia expands BEPS MLI coverage through 22 additional treaties
According to an OECD update, Georgia submitted an updated consolidated position for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) on 27 November 2025. The update notably expands the list of Georgia’s
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OECD reports increase in MAP and APA caseloads in 2024 data published on Tax Certainty Day 2025
The OECD has released new tax dispute statistics, highlighting generally positive results despite ongoing challenges on 31 October 2025. Tax certainty: OECD releases new statistics on tax disputes, showing positive outcomes but with challenges
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Australia: Federal Court pauses Oracle royalty tax case to permit treaty arbitration with Ireland
The Full Federal Court of Australia ruled in favour of Oracle, allowing its Mutual Agreement Procedure with Ireland to proceed by staying domestic tax proceedings, reaffirming taxpayers’ treaty rights to prevent double taxation over intra-group
See MoreOECD: Australia, Belgium, Netherlands, New Zealand revise arbitration rules under BEPS MLI
Part VI of the MLI enables jurisdictions that opt in to implement mandatory binding arbitration to resolve disputes arising under tax treaties. The OECD has released updated arbitration profiles for Australia, Belgium, Netherlands, and New
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Peru: BEPS MLI enters into force
Peru’s BEPS MLI entered into force on 1 October 2025 to curb tax treaty abuse and base erosion by multinationals. The Multilateral Convention on Tax Treaty Measures to Counter Base Erosion and Profit Shifting (MLI) has entered into force in
See MoreArgentina deposits BEPS MLI ratification instrumentÂ
The MLI is set to take effect in Argentina starting 1 January 2026. Argentina officially ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) by depositing its instrument
See MoreGeorgia expands BEPS MLIs coverage with 22 new tax treaties
Georgia's Parliament Foreign Relations Committee approved ratifying several international agreements, including an update to Georgia's MLI reservations and notifications originally submitted on 29 March 2019. The Foreign Relations Committee of
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OECD updates BEPS Action 5 transparency framework on tax rulings
OECD updated BEPS Action 5 rules with new peer review terms and XML Schema for 2027. The OECD released a set of revisions to the BEPS Action 5 minimum standard on the spontaneous exchange of information on tax rulings (the “transparency
See MoreAustralia, New Zealand agree on arbitration framework under BEPS MLI
The Memorandum of Arrangement sets out rules for arbitration requests, required information, arbitrator appointments, and the overall arbitration process. The Australian Taxation Office (ATO) and New Zealand signed a Memorandum of Arrangement
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Peru to implement BEPS multilateral instrument
Peru will implement the BEPS Multilateral Instrument from 1 October 2025, with application to tax treaties depending on counterparties’ ratifications. Peru’s Ministry of Foreign Affairs published a notice on 23 August 2025 in a special
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OECD highlights progress and burden reduction on BEPS standards
The OECD/G20 Inclusive Framework report endorsed practical adjustments to ease the BEPS minimum standards' administrative burdens. RegFollower Desk The OECD reported on 4 July 2025 that the members of the OECD/G20 Inclusive Framework has
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