Poland: Senate passes transfer pricing, business tax reporting reforms
Poland's Senate (Upper house of Parliament) passed a legislation that reshapes how small businesses handle tax reporting and cash transactions. The Act of 18 September 2026, transmitted as Senate Print No. 834 (Druk nr 834), amends both the
See More
Australia: ATO updates GILTI guidance following US tax regime changes
The Australian Taxation Office (ATO) has issued an Addendum to Taxation Determination TD 2022/9 by the Commissioner of Taxation on 23 September 2026 to account for amendments to the US global intangible low-taxed income (GILTI) regime introduced
See More
Latvia: SRS issues transfer pricing controlled transaction report guidance
Latvia’s tax authority, the State Revenue Service, on 18 September 2026, issued the methodological guidance covering transfer pricing controlled transaction report requirements. These documents provide official guidelines from the Latvian State
See More
Netherlands updates interest deduction limitation rules
The Netherlands published Policy Decision No. 2026-17016 of 10 September 2026 from the State Secretary of Finance on 22 September 2026, updating and replacing the 2025 decision on the interest deduction limitation, or earnings stripping,
See More
Ukraine proposes broad transfer pricing reforms
The Ukrainian Parliament is reviewing the draft Law on amendments to the tax code of Ukraine regarding further improvement of Transfer Pricing (TP) rules, which was submitted on 4 September 2026. If adopted, the lew would enter into force on 1
See More
Australia: Federal Court upholds AUD 173.3m tax benefit adjustment against Hilton
The Federal Court of Australia rejected Hilton International Australia Pty Ltd's challenge to the Commissioner of Taxation on 9 September 2026 (Case: Hilton International Australia Pty Ltd v Commissioner of Taxation (No 2) FCA 1325). Justice Younan
See More
Panama: DGI extends transfer pricing report filing deadline for specified taxpayers
Panama’s tax authority (DGI) has published Resolution No. 201-6989 (issued on 2 September 2026) in the Official Gazette on 8 September 2026 extending the deadline for filing the Transfer Pricing Report (Form 930) for taxpayers operating under a
See More
Belgium hosts webinar clarifying updated BEPS 13 transfer pricing forms filing requirements, CbC reporting
Belgium's tax authorities hosted a webinar attended by over 200 participants to address technical implementation requirements for updated BEPS 13 reporting forms on 7 September 2026. The session covered the country-by-country (CbC) notification
See More
Iceland: MoF consults tax law changes on interest deductions, charities, rulings and nicotine products
Iceland’s Ministry of Finance and Economic Affairs (MoF) has initiated a public consultation on several proposed legislative amendments in its draft document on 4 September 2026, with a targeted entry into force on 1 January 2027. These planned
See More
Malaysia gazettes Income Tax (Transfer Pricing) (Amendment) Rules 2026
Malaysia’s government has published Order No. P.U. (A) 300/2026, the Income Tax (Transfer Pricing) (Amendment) Rules 2026, in the Official Gazette on 27 August 2026, officially updating Malaysia's regulatory framework regarding transactions
See More
Ireland: Revenue clarifies Section 110 transfer pricing, profit participating note rules
Ireland Revenue has clarified the application of Section 110 of the Taxes Consolidation Act (TCA) 1997, including Transfer Pricing, arm's length requirements and restrictions on profit participating notes (PPNs), in eBrief 120/2026 published on 21
See More
Morocco announces ratification of MCAA-CbC
Morocco published Royal Decree No. 1.26.72 in the Official Gazette on 12 August 2026, promulgating Law No. 76.19, which ratifies the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA). The law
See More
Australia: ATO tightens CbC reporting exemptions, extends administrative relief indefinitely
The Australian Taxation Office (ATO) has implemented significant updates to its Country-by-Country (CbC) reporting exemptions and administrative relief guidelines for requests received from 1 January 2025. It details the specific criteria and
See More
Montenegro issues rulebook on cross-border tax reporting, transfer pricing
Montenegro’s government has published Rulebook No. 10/1-1-01-040/26-2637/4 in the Official Gazette on 7 August 2026, clarifying the automatic exchange of information (AEOI) with EU member states and the European Commission (EC) on previous
See More
South Africa: SARS issues rules for DTA advance pricing agreement system
South Africa has introduced a detailed framework for its Double Taxation Agreement (DTA) advance pricing agreement (APA) system through six income tax notices covering applicant eligibility, fees, rejection grounds, processing requirements,
See More
Luxembourg: Administrative Court rules on transfer pricing treatment of debt restructuring
The Luxembourg Administrative Court (Cour administrative) issued its decision in case 53194C on 22 July 2026, concerning the application of the arm’s length principle to an intra-group debt restructuring and the deductibility of interest
See More
India publishes 25-26 APA report highlighting record agreements
India's Income Tax Department has released the Advance Pricing Agreement (APA) Programme Annual APA Report FY 2025-26, detailing record activity under the country's APA programme, legislative reforms that took effect on 1 April 2026, and progress in
See More
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
See More