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Industrial data and transfer pricing: navigating the smart factory shift
As manufacturers adopt smart factory technologies, the data generated by industrial IoT systems, automated production lines, and digital twins is…
EY US and the unfinished business of India’s secondment doctrine
This article examines the ongoing development of India's secondment doctrine in the context of EY US, addressing how cross-border employee…
Cyprus: OECD Reshapes Transfer Pricing and Treaty Benefits
Cyprus is adapting its transfer pricing framework and tax treaty benefit rules in response to OECD developments, including BEPS-driven standards.…
When a Promise Becomes Taxable: What the Torrent Power Judgment Really Means for Corporate Guarantees
The Torrent Power judgment addresses a significant transfer pricing question: whether corporate guarantees provided by parent companies to subsidiaries constitute…
Seabrooke & Stausholm: How TaxTech Rewires Global Wealth Chains
Academic research by Seabrooke and Stausholm examines how tax technology is reshaping global wealth chains, exploring the intersection of digital…
DT-06-2025: Estudio sobre Inteligencia Artificial aplicada a los precios de transferencia (Ahora disponible en inglés))
CIAT has published a study (DT-06-2025) on the application of artificial intelligence to transfer pricing, now available in English. The…
Taxation in Vietnam: what foreign investors need to know
Vietnam's tax framework presents several key considerations for foreign investors. The country imposes corporate income tax at a standard rate…
Protecting the Tax Base: KRA’s Progress in International Taxation
This article examines the Kenya Revenue Authority's (KRA) efforts to protect Kenya's tax base through international taxation measures. The KRA…
Diving into the Differences Between Tax Transparency Regimes
This article examines the differences between various tax transparency regimes, likely covering OECD-led initiatives such as the Common Reporting Standard…
Allahabad HC: Objections to Draft Assessment Order Must Be Filed Before Both DRP and AO
The Allahabad High Court has ruled that taxpayers contesting a draft assessment order must file objections before both the Dispute…
The increasing importance of ‘economic substance’ under Indian income tax laws
India's income tax framework is placing growing emphasis on economic substance requirements, reflecting a broader shift in how tax authorities…
Can an individual fall within the scope of transfer pricing? Yes – and sooner than you think
This article examines whether individuals can fall within the scope of transfer pricing rules, with a focus on Poland. It…
VAT Committee: Transfer Pricing Adjustments at Variable Prices May Be Relevant
The EU VAT Committee has issued guidance indicating that transfer pricing adjustments in variable pricing arrangements may carry VAT relevance.…
Romania Introduces New Transfer Pricing Documentation Requirements under Order 828/2026
Romania has introduced new transfer pricing documentation requirements under Order 828/2026, updating obligations for taxpayers operating in the country. The…
N.Y. Times: Crocs Has a Trick for Dodging Taxes: a Tiny Office in Malta
Crocs, the footwear company, reportedly uses a small office in Malta to reduce its tax burden, according to a New…
Beyond the price: key transfer pricing controversies in the Andean region
This article examines key transfer pricing controversies across the Andean region, covering countries such as Colombia, Peru, Ecuador, and Bolivia.…
TP in the Southern Cone: substance, business transformation, and global tax challenges
This article analyzes transfer pricing developments in the Southern Cone, focusing on Argentina, Chile, Uruguay, and Paraguay. It addresses the…
Multinationals brace for more tax disputes: Baker McKenzie survey
A Baker McKenzie survey reveals that multinational corporations are anticipating a significant rise in tax disputes globally. The research highlights…
Key challenges in the transfer pricing of financial transactions
Financial transactions represent one of the most complex areas of transfer pricing, encompassing intercompany loans, cash pooling, guarantees, and treasury…
TP in Peru: where global profitability policies meet a transaction-by-transaction regime
Peru's transfer pricing regime requires a transaction-by-transaction analysis, creating tension with multinational groups that apply global profitability policies across their…
How the Keysight Decision Could Affect the Kwong Appeal
The Keysight decision is a significant transfer pricing case that could influence the outcome of the Kwong appeal. The article…
A Polish tax roadmap for foreign investors based on how audits evolve
This article provides a practical guide for foreign investors navigating Poland's tax environment, structured around how Polish tax audits typically…
CIAT apoya mesa técnica regional para el intercambio de experiencias en precios de transferencia
CIAT is supporting a regional technical roundtable focused on the exchange of experiences in transfer pricing among Latin American tax…
Transfer Pricing and VAT Developments
This article examines recent intersecting developments in transfer pricing and VAT, highlighting how intragroup transactions are increasingly scrutinized under both…
One Ruling, Many Jurisdictions: Stellantis VAT Judgment Reaches Swiss Tax Guidance
The Stellantis VAT judgment has generated cross-border ripple effects, with Swiss tax authorities issuing guidance in response to the ruling.…
UAE Flips the Valuation Problem Upside Down: A Top-Down Method for Costing Deemed Supplies of Services
The UAE has introduced a top-down valuation methodology for deemed supplies of services, addressing a longstanding challenge in VAT compliance.…
2025 Transfer Pricing Year in Review
KPMG's 2025 Transfer Pricing Year in Review examines how multinational enterprises are navigating a rapidly evolving global transfer pricing landscape…
Bloomberg: Amgen Settles Investor Suit Over Tax Liability for $74 Million
Amgen has settled an investor lawsuit for $74 million related to disclosures about its tax liabilities. The case centered on…
Avi-Yonah: Taxation and Deglobalization
Professor Reuven Avi-Yonah examines the intersection of taxation and deglobalization, exploring how the retreat from global economic integration is reshaping…
Amgen To Pay $74M To End Investor Suit Over $10.7B Tax Bill
Amgen has agreed to pay $74 million to settle an investor lawsuit stemming from a $10.7 billion IRS tax bill…
OECD Chapter VII Consultation: Is Cost Plus 5% Still Defensible for Headquarters Services?
The OECD's ongoing consultation on Chapter VII of the Transfer Pricing Guidelines is prompting fresh scrutiny of the cost plus…
OECD Consultation on Intra-Group Services Guidelines
The OECD has launched a public consultation on updated guidelines governing intra-group services, a key area of transfer pricing that…
Form: International Tax: UK-USA Double Taxation Convention (form US-Company UK-REIT)
This HMRC form relates to the UK-USA Double Taxation Convention, specifically for US companies receiving income from UK Real Estate…
Guidance: Country-by-country: service availability and issues
HMRC guidance on the availability and known issues with the Country-by-Country (CbC) reporting service, used by large multinational enterprises to…
Outdated Transfer Pricing Policies Create New Risks
Outdated transfer pricing policies pose significant risks for multinational companies as global tax environments evolve rapidly. Policies drafted years ago…
The End of the Cost-Plus 5% Regime for Headquarters? OECD Consultation Paper on Value-Based Pricing of Intercompany Services
The OECD has released a consultation paper proposing a shift away from the traditional cost-plus 5% pricing method for intercompany…
Webinar: Navigating transfer pricing audits in Southeast Asia
PKF is hosting a webinar focused on navigating transfer pricing audits across Southeast Asia. The session is designed to help…
N.Y. Times: Microsoft Disclosure Provides Rare Glimpse of Tax Haven Tactics
The New York Times reports on a rare Microsoft disclosure revealing the company's use of tax haven strategies to minimize…
Register Now: Taxand Asia Webinar: Interest-Free Loans: Current Positions and Evolving Treatment Under TP Rules
Taxand Asia is hosting a webinar focused on interest-free loans and their treatment under transfer pricing rules. The session will…
Tax Inspectors Without Borders strengthening tax systems through new South-South co-operation
Tax Inspectors Without Borders (TIWB), a joint OECD and UNDP initiative, is expanding its South-South cooperation model to strengthen tax…
UK: HMRC Consults on International Controlled Transactions Schedule
HMRC has launched a consultation on a new International Controlled Transactions Schedule, which would require UK businesses to report detailed…
The UAE’s New Transfer Pricing Regime: From a Tax-Free Reputation to Arm’s Length Compliance
The UAE has introduced a formal transfer pricing regime following the implementation of corporate tax in 2023, marking a significant…
Comments on ECJ C-603/24 (Stellantis Portugal) – Transfer pricing and VAT: Court confirms in Stellantis that not every true-up constitutes a service
The European Court of Justice ruled in case C-603/24 (Stellantis Portugal) that not every transfer pricing true-up payment constitutes a…
Herzfeld: “SpaceX Speculation: Who Bears the Risk?”
This article by Herzfeld examines transfer pricing and risk allocation issues related to SpaceX, analyzing who bears economic risk in…
Coca-Cola Meets Sympathetic Judges in $20 Billion IRS Case
Coca-Cola's long-running $20 billion tax dispute with the IRS received a potentially favorable reception from appellate judges, signaling possible relief…
The Role of Contractual Arrangements in Transfer Pricing: Insights from Case Law and Practice
This article examines how contractual arrangements function within transfer pricing frameworks, drawing on case law and practical insights. It explores…
Mumbai ITAT Reiterates: No Further Profit Attribution to Foreign Enterprise Once Indian AE Is Remunerated at Arm’s Length
The Mumbai ITAT reiterated the principle that once an Indian associated enterprise (AE) is remunerated at arm's length, no further…
Assessing Nigeria’s Alignment with International Tax Standards: Adoption, Implementation, Relevance and Impact
This publication evaluates how Nigeria has aligned its domestic tax framework with international tax standards, examining adoption, implementation, relevance, and…
International Exchange of Information Manual
HMRC's International Exchange of Information Manual covers the legal frameworks and procedures governing the automatic and on-request exchange of taxpayer…
The Supreme Court Ruling and the Potential for Tariff Refunds: Their Impact on Transfer PricingA view from transfer pricing practitioners
This article examines the intersection of tariff refunds stemming from a Supreme Court ruling and transfer pricing, written from a…
Meta Says IRS Seeks 'Do-Over' Of Facebook Case
Meta is challenging the IRS in a high-stakes transfer pricing dispute over the Facebook case, arguing that the IRS is…
India’s New Safe Harbour Rules Are Prompting a Reassessment of Transfer Pricing Strategies
India's updated safe harbour rules are reshaping how multinational companies approach transfer pricing strategies. The revised framework provides taxpayers with…
Transfer Pricing: International Controlled Transactions Schedule
HMRC is consulting on a new International Controlled Transactions Schedule (ICTS) for transfer pricing in the UK. The proposal requires…
Double Taxation Relief Manual
HMRC's Double Taxation Relief Manual provides comprehensive guidance for tax professionals on the UK's framework for relieving double taxation. It…
International Manual
HMRC's International Manual is a comprehensive guidance resource covering the UK's international tax rules for tax professionals and HMRC officers.…
Why Global Structuring and Transfer Pricing Matter for Life Sciences Companies
This article examines the critical importance of global structuring and transfer pricing for life sciences companies, which face unique challenges…
Payroll pulse: Navigating permanent establishment risk with remote workers in 2026
This article examines the growing permanent establishment (PE) risks that arise when employees work remotely across borders, a challenge intensifying…
Orbitax Launches Australia Public CbC Reporting Solution
Orbitax has launched a dedicated solution to assist multinational enterprises in complying with Australia's public Country-by-Country (CbC) reporting requirements. Australia's…
Transfer Pricing in Practice
This article from Quantera Global explores practical aspects of transfer pricing, addressing how multinational enterprises (MNEs) structure and document intercompany…
Germany’s Transaction Matrix Requirement Is Reshaping Transfer Pricing Compliance
Germany has introduced a Transaction Matrix requirement that is significantly transforming transfer pricing compliance obligations for multinational enterprises operating in…
Global Rules, Local Realities: Lessons from the Global South on International Tax Standards
This article examines how international tax standards developed primarily by OECD nations affect Global South countries, highlighting the tension between…
CJEU Narrows VAT Exposure for Transfer Pricing Adjustments in Stellantis Portugal Case
The Court of Justice of the European Union (CJEU) has issued a significant ruling in the Stellantis Portugal case, narrowing…
The UK’s Transfer Pricing Landscape Is Entering a New Era of Scrutiny
The UK's transfer pricing regime is undergoing significant transformation, with HMRC intensifying scrutiny of intercompany transactions amid legislative reforms. The…
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