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Europe
- Poland: Bill providing for simplification of transfer pricing reporting on intra-group transactions adopted by lower house of Parliament – click here;
- Poland: Public country-by-country reporting (CbCR) – practical challenges and lessons learnt – click here;
- UK: International controlled transactions schedule (ICTS) intended to apply beginning January 1, 2027 – click here;
- UK: HM Revenue & Customs’ (HMRC) approach and recent cases – click here;
- Finland: Government proposes lower corporate tax rate, longer loss carry-forward period from 2027 – click here;
- France: Council of Ministers approves protocol amending tax treaty with India – click here;
- Latvia: State Revenue Service (SRS) issues transfer pricing controlled transaction report guidance – click here;
- Belgium: Belgian Constitutional Court allows landmark Undertaxed Profits Rule (UTPR) case (Pillar Two) to continue before the Court of Justice of the European Union (CJEU), despite side-by-side (SbS) package – click here;
- Netherlands: Netherlands updates interest deduction limitation rules – click here;
- Cyprus: A recap of tax obligations for companies belonging to large multinational enterprise (MNE) groups – click here;
- Europe: Guarantees and implicit support – a new front in transfer pricing controversy – click here;
- Europe: Member States raise concerns over scope and impact of Tax Omnibus – click here;
- Europe: Court of Justice of the European Union (CJEU) rules on neutralization of dividend withholding tax restriction by tax treaties – click here;
Global
- Global: Potential permanent establishment, transfer pricing challenges associated with mobile workers – click here;
- Global: Revisiting the use of statistical ranges in transfer pricing – click here;
- Global: Rethinking transfer pricing controversy in a time of transformation – click here;
- Global: Transfer pricing auditing in the tech environment – click here;
- Global: Integration, digitalisation, and the arm’s-length principle – click here;
- OECD: Aspiration to practicalities – what the 2026 mutual agreement procedure (MAP) manual means for tax certainty – click here;
- OECD: Inclusive Framework releases a package to strengthen consistency and certainty for multinational enterprises (MNEs) and jurisdictions – click here and here;
- US: Transfer pricing and international tax year-end considerations – click here;
- US: US path to Amount B adoption – why Internal Revenue Service (IRS) notice marks key step – click here;
- US: Weighing the risk – US tax reforms driving multinational enterprises (MNEs) to reassess intellectual property (IP) models – click here;
- US: Kansas Republican introduces amendments to international tax system, proposes base erosion and anti-abuse tax (BEAT), net CFC tested income (NCTI) and foreign-derived deduction eligible income (FDDEI) changes – click here;
- Brazil: Amended qualified domestic minimum top-up tax (QDMTT) regulations introduce substance-based tax incentive safe harbor – click here;
- Mexico & Colombia & Peru & Brazil & Chile: Transfer pricing trends in an era of heightened tax controversy – click here;
- Hong Kong: Hong Kong announces 2026 Policy Address, unveils corporate tax incentives and family tax relief – click here;
- Australia: Australian Taxation Office (ATO) reports strong tax compliance among large businesses in 2025-26 – click here;
TP Cases
- Greece: Interest on intragroup loan obtained for dividend distribution is not tax deductible – click here;
- Denmark & UK: EU advisory commission rules UK wind farms primarily taxable in the UK – click here and here;
- India: Transfer pricing at year-end – one comparable, one allocation and several red flags – click here;
Webinars
- OECD: Public consultation meeting – revisions to Chapter VII of the OECD Transfer Pricing Guidelines, 9th of November 2026 – click here;
Romania
- Romania: NAFA compliance notifications on net profit margins: What to check before replying – click here;
- Romania: Draft governing programme: NAFA could assign a risk score to each taxpayer – click here;
- Romania: European Commission’s Tax Omnibus: Wider withholding tax exemptions and fewer DAC6 reporting obligations – click here;
- Romania: Draft law B471/2026: Cancellation of interest and penalties extended to tax liabilities assessed in later NAFA audits – click here;
- Romania: DAC7 and form F7000: How NAFA uses digital platform reporting to check sellers' tax obligations – click here;
- Romania: NAFA Order 828/2026: Large taxpayers to submit the transfer pricing file annually – click here.
