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
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
On 25 May 2021 the OECD released a further batch of eight Stage Two peer review reports in relation to making dispute resolution mechanisms more effective under BEPS Action 14. The minimum standard under BEPS action 14 is concerned with
