India: Tax Authority appeals high court ruling on treaty limits to dividend tax
The Indian Income Tax Department filed a special leave petition before the Supreme Court on 30 January 2026, challenging a Bombay High Court ruling that held Dividend Distribution Tax (DDT) could be limited by applicable tax treaties. The appeal
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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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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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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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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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Malta issues updated guidelines for mutual agreement procedure
Malta's Commissioner for Revenue has issued the updated guidelines on Mutual Agreement Procedure (MAP) Guidelines on 11 March 2025. These guidelines explain how the MAP functions, allowing Malta’s Competent Authority to collaborate with
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Chile revises procedures for transfer pricing adjustment requests
Chile's Internal Revenue Service (SII) has published Resolution No. 6 of 9 January 2025, which updates procedures for requesting transfer pricing adjustments after adjustments by foreign tax authorities. It updates and replaces Resolution No. 67
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US, Norway Competent Authority Arrangement (CAA) enters into force
The US Internal Revenue Service (IRS) has issued Announcement 2024-42 on 9 December 2024 in which it notified taxpayers the US and Norway has entered a competent authority arrangement (CAA) in accordance to the paragraph 2 of Article 27 (mutual
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UK considers changes to transfer pricing, advance pricing rules in Autumn Budget 2024
UK’s Chancellor of the Exchequer Rachel Reeves, in her Autumn Budget 2025 announcement on 30 October 2024, said her government is considering modernising the country’s transfer pricing rules and the advance pricing agreement system. Reeves
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Bahamas issues MAP guidance with Japan
The Bahamas Ministry of Finance has released guidance on Mutual Agreement Procedures (MAP) with Japan as per the tax information exchange agreement between the two nations. The guidance details the scope of MAP, eligibility for requesting MAP,
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US: IRS releases 2025 HSA inflation-adjusted amounts
The US Internal Revenue Service (IRS) published on Thursday, 9 May, 2024, the Rev. Proc. 2024-25, in which it detailed the inflation-adjusted limits for Health Savings Accounts (HSAs) and High Deductible Health Plans (HDHPs) for the 2025 calendar
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Ukraine reports 2023 transfer pricing adjustments results and penalty relief
On 22 February 2024, the State Tax Service of Ukraine published a release about the outcome of the transfer pricing adjustments in 2023. The release mentioned that from 1 August 2023 until the conclusion of martial law in Ukraine, taxpayers can
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Malaysia publishes surcharge FAQs related to transfer pricing adjustments
On 18 January 2024, the Inland Revenue Board of Malaysia (IRBM) published an FAQ list about surcharges for transfer pricing adjustments. The FAQ document is available on the transfer pricing guidance webpage. Under the Finance Act 2020, the tax
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Russia announces transfer pricing changes from 2024
On 27 November 2023, Russia issued Law No. 539-FZ in the Official Gazette, which outlines several amendments to the country’s transfer pricing regime. A summary of several key changes is outlined below: Secondary adjustments treated as
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Saudi Arabia: ZATCA releases drafts of new income tax and tax procedural laws for public consultation
On 25 October 2023, Saudi Arabia’s Zakat, Tax and Customs Authority (ZATCA) issued drafts of a new Income Tax Law and Zakat and Tax Procedures Law for public consultation. The public consultation period for comments on the drafts is open until 25
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Israel releases Guidance on MAP and APA procedures
On 17 August 2023, the Israel Tax Authority (ITA) released Tax Circular No. 1/2023, which provides guidance for mutual agreement procedure (MAP), and bilateral advance pricing agreement (APA) requests. The new circular replaces the guidance of
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Georgia adopts rules on Mutual Agreement Procedures (MAP)
The Ministry of Finance of Georgia recently published Decree No. 258 of July 2023, which approves the rules for the Mutual Agreement Procedures (MAP) under the Tax Treaties of Georgia or the provisions of the BEPS MLI. The rules encompass various
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