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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Peru: Government raises tax unit value for 2026
Peru’s government, through Supreme Decree No. 301-2025-EF issued on 17 December 2025, has set the Tax Unit (Unidad Impositiva Tributaria – UIT) for 2026 at PEN 5,500, up from PEN 5,350. The UIT is a key reference in the country’s tax
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Armenia approves addendum to CRS multilateral agreement, includes crypto-asset reporting
Armenia approved an update to its international tax reporting system by signing the Addendum to the CRS MCAA on 8 January 2026, expanding the information financial institutions must report, including holdings in crypto-assets, and tightening due
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Colombia: DIAN publishes 2026 tax calendar with income tax, VAT, transfer pricing deadlines
Colombia’s National Directorate of Taxes and Customs (DIAN) published the 2026 tax calendar on 26 December 2025, outlining the deadlines and dates that individuals, legal entities and other taxpayers must follow to comply with their national tax
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Singapore: IRAS updates transfer pricing guidance, raises indicative margin for related party loans
The Inland Revenue Authority of Singapore (IRAS) has updated its Transfer Pricing guidance for 2026 on 2 January 2026, including the indicative margin for related party loans. For the year 2026, the indicative margin applicable to Risk-Free Rates
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Iceland: Revenue and Customs announces 2025 CbC report submission deadline
Iceland’s tax authority, the Revenue and Customs, has published a notification regarding the annual filing of the Country-by-Country (CbC) report on 25 November 2025. Pursuant to Act no. 90/2003 on income tax, entities subject to
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Croatia updates tax ordinance on automatic exchange of information (AEOI)
Croatia published Ordinance No. 2396 in the Official Gazette on 31 December 2025, amending the rules governing the automatic exchange of tax-related information (AEOI). The ordinance expands reporting obligations for financial institutions,
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Singapore: IRAS expands list of jurisdictions for CbC exchange
The Inland Revenue Authority of Singapore (IRAS) has updated the list of jurisdictions with which Singapore will exchange Country-by-Country (CbC) reports under the Multilateral Competent Authority Agreement on Automatic Exchange of
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The Inland Revenue Authority of Singapore (IRAS) has released the third edition of its e-Tax Guide on the Income Tax Treatment of Hybrid Instruments on 26 December 2025. The guide outlines how hybrid instruments are classified as debt or equity
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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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UAE: FTA updates corporate advance pricing agreements guidance
The UAE Federal Tax Authority (FTA) has released a new Corporate Tax Guide on Advance Pricing Agreements (CTGAPA1) in December 2025. The guide outlines the procedural framework for APAs and covers an overview of the APA programme, applicable
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