Ukraine: MoF consults transfer pricing reform bill
Ukraine’s Ministry of Finance (MoF) opened a public consultation on a draft law titled “On Amendments to the Tax Code of Ukraine Regarding Further Improvement of Transfer Pricing Rules” on 24 February 2026. The draft was prepared with the
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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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Poland: Court rules deferred tax regime doesn’t exempt companies from transfer pricing rules
Poland's Supreme Administrative Court has ruled that companies using the deferred corporate income tax regime must comply with transfer pricing rules, including Local File documentation requirements. This ruling details a judgment from the
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OECD releases Amount B Pillar One guidance, pricing automation tool
The OECD published new materials on 17 February 2026 to assist with the rollout of Amount B under Pillar One, which provides a simplified transfer pricing framework for baseline marketing and distribution activities. The release includes updated
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OECD introduces manual on mutual agreement procedures via technical webinar
The OECD hosted a technical webinar on the revised Manual on Effective Mutual Agreement Procedures (MEMAP) on 10 February 2026, in support of the broader focus of the BEPS Inclusive Framework and the Forum on Tax Administration (FTA) on improving
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Colombia: DIAN highlights 2025 transfer pricing adjustment requirements
Colombia’s tax authority (DIAN) has issued a notification, on 6 February 2026, for large taxpayers subject to the transfer pricing regime to make any required transfer pricing adjustments when filing their 2025 fiscal year income tax return. As
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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
See MorePoland 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
See MoreOECD 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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