Date View Archive | stevetowers.tax

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News & Views Archive

Friday, December 19

Global: Arm’s length without a market (Ajit Jain on LinkedIn) More
Global: EU seems ready to move forward with OECD's pillar 2 plan (Błażej Kuźniacki on LinkedIn) More
Global: Peer review results on BEPS Action 5 (KPMG) More
Global: The Pillar Two origin story (Part 3) (PwC podcast, 48:17) More
Argentina: Argentina updates transfer pricing compliance obligations (EY) More
Australia: Pillar Two: From policy to practice—Latest ATO guidance (Deloitte) More
Belgium: Law including key employment and individual tax reforms approved by parliament (Deloitte) More
Belgium: Second phase of Belgian tax reform approved by Parliament (Loyens & Loeff) More
Brazil: Brazilian tax authority issues guidance on new withholding tax on dividends paid to non-residents (EY) More
Canada: Canada tables bill with accelerated capital cost allowance and other immediate expensing measures (EY) More
China: Beyond zero tariffs – What Hainan’s new customs zone means for industry, investors, and the island (Dezan Shira and Associates) More
Egypt: Egypt unveils second tax facilitation package to ease procedures, boost compliance (Regfollower) More
Ethiopia: Ethiopia issues a new Income Tax Proclamation (EY) More
EU: ECOFIN approves interim EUR 3 customs levy for small parcels (Deloitte) More
Ghana: Deduction at source for VAT paid to non-residents on digital services considered (Deloitte) More
Ireland: Ireland's Pillar Two registration deadline is extended (EY) More
Jersey: Draft regulations implementing cryptoasset reporting framework (KPMG) More
Malaysia: Compliance review framework for e-invoicing (KPMG) More
Netherlands: Consultation on changes to definition of mutual fund and introduction of an opt-out scheme (KPMG) More
Romania: Amendments to fiscal code and introduction of new logistics fee (KPMG) More
Serbia: Amendments to e-invoicing law (KPMG) More
Spain: Tax newsletter (November 2025) (Garrigues) More
US: Final and proposed guidance relating to s. 892 tax exemption for foreign governments (Deloitte) More
US: Treasury releases final regulations on qualified derivative payments for BEAT purposes (PwC) More
Vietnam: Guidance on new corporate income tax law (KPMG) More

Thursday, December 18

Global: Global minimum tax agreement in jeopardy (Alex Parker) More
Global: Latest on BEPS and beyond (EY) More
Global: Transfer pricing – interquartile range and median (Borys Ulanenko on LinkedIn) More
Australia: CARF to be implemented from 2027, first exchanges with other tax authorities in 2028 (Deloitte) More
Australia: Mid-Year Economic and Fiscal Outlook 2025-26 tax summary (Deloitte) More
Belgium: Updated draft law on new capital gains tax on financial assets (KPMG) More
Croatia: Amendments to local Pillar Two rules adopted (KPMG) More
Estonia, Latvia, Lithuania, Malta, and Slovakia: 5 small EU Member States call on the EU to extend their deferral of the introduction of the EU GloBE Directive (Estonian government press release) More
EU: E-News from KPMG’s EU Tax Centre (KPMG) More
EU: ECOFIN approves two reports on tax-related initiatives and 2025 Code of Conduct Group conclusion (KPMG) More
EU: EU Tax Directives #6: Repeal of 3 proposed EU Tax Directives (Loyens & Loeff) More
EU: European Commission releases EU “tax gap” report (Commission) More
France: Additional Pillar Two guidance (KPMG) More
India: Head office expenses and input tax credit provisions (court decisions) (KPMG) More
Kenya: Kenya Revenue Authority publishes draft regulations on Minimum Top-Up Tax (EY) More
Liechtenstein, Switzerland, and US: US revises tariffs on products from Liechtenstein and Switzerland (KPMG) More
Malaysia: Tax highlights of bills that include measures beyond those announced in Budget 2026 (Deloitte) More
Poland: Amendments to corporate income tax for banks and exemptions for investment funds (KPMG) More
South Africa: Requirements for certain unlisted companies to qualify as a REIT (KPMG) More
Turkey: Extension of QDMTT return filing deadline (KPMG) More
UK: Hotel La Tour Supreme Court decision: no VAT recovery on share sale deal fees (Slaughter and May) More
US: 3M – when courts say no (Baker McKenzie) More
US: Final regulations: Base erosion and anti-abuse tax (BEAT) rules for qualified derivative payments (QDPs) on securities lending transactions (KPMG) More
US: Highlights of regulations taxing the income of foreign governments from investments in the US (PwC) More
US: Looking ahead to 2026—CAMT and asset management (KPMG) More
US: Navigating the new powerful tax incentive for US production facilities under section 168 (Alvarez & Marsal) More
US: Pillar Two: Key compliance obligations for US MNEs (Loyens & Loeff) More
US: Tax Court holds that relevancy determination is required to apply Section 7701(o) (Baker McKenzie) More
US: Treasury Department finalizes long-awaited section 892 regulations (Baker McKenzie) More

Wednesday, December 17

Global: Global e–invoicing developments tracker (10 December 2025) (EY) More
Global: Home office or business hub? (Deloitte) More
Global: Tax treaty round-up (Deloitte) More
Global: US Treasury Secretary’s post on X relating to GloBE side-by-side negotiations (US government) More
Australia: Mining and petroleum: updated guidance for consultation (Tax authorities) More
Australia: Weekly tax round-up (Deloitte) More
France and India: India-France tax treaty update favours long-term investors, expands capital gains rights (Dezan Shira and Associates) More
Gibraltar: Gibraltar to introduce Pillar Two registration and local Top-up Tax Return (EY) More
Netherlands: Consultation proposal to amend the FGR regime (Loyens & Loeff) More
Netherlands: Dutch tax classification of (non-)Dutch limited partnerships – current state of play (Loyens & Loeff) More
Netherlands: Interest expenses non-deductible when debt acquisition abuses law (Supreme Court decision) (KPMG) More
New Zealand: Emissions Trading Scheme for non-forestry industries (Deloitte) More
New Zealand: NZ's R&D tax incentive regime - 5 years on (Deloitte) More
New Zealand: Software development and SaaS expenditure under the policy spotlight (Deloitte) More
Singapore: Updates to tax incentive subsidiary legislation (Deloitte) More
US: Expanded s. 4960 “covered employees” definition for excise tax on excess compensation (Deloitte) More
US: Trade lines: policy intelligence for global business leaders (EY) More
US: US Court of International Trade clarifies refund pathway for IEEPA tariffs, denies preliminary injunction in IEEPA-related refund case (EY) More

Tuesday, December 16

Global: Global tax talk – tax in 60 seconds (Will Morris on LinkedIn) More
Global: Pillar Two update: delays, dissent, and the “safe harbour” patchwork (Neil Pereira on LinkedIn) More
Global: The future of transfer pricing controversy - an AI arms race? (Joel Cooper on LinkedIn) More
Global: Trade talking points (EY) More
Australia: ATO issues final guidelines for exemptions to Public CbC reporting (Deloitte) More
Australia: ATO releases draft PCG on TP issues related to inbound distribution arrangements (Deloitte) More
Belgium: Law containing miscellaneous provisions approved by Parliament (KPMG) More
Belgium: Parliament endorses tax reform targeting investment company share gains (Regfollower) More
Bermuda: Parliament adopts Tax Credits Act 2025 and Corporate Income Tax Amendment (No. 2) Act 2025 (EY) More
Brazil and Netherlands: A-G opinion Dutch Supreme Court - Brazilian interest on net equity (Rhys Bane on LinkedIn) More
Denmark: Global Services A/S case – transfer pricing – business restructuring – valuation of intangibles – in Danish (TPcases) More
Egypt: Instructions clarify procedures to offset VAT credits against tax debit balances (Deloitte) More
EU: European Commission publishes December 2025 infringements package (Deloitte) More
EU: Small consignments entering EU subject to fixed customs duty beginning July 1, 2026 (KPMG) More
France: Pillar Two: Latest FTA guidance (Deloitte) More
Germany: Withholding tax on dividends paid by German hybrid entities (KPMG) More
Italy: Protest breaks out over 2026 budget proposal (Regfollower) More
Italy: VAT audit focus on year-end transfer pricing adjustments (EY) More
Kenya: Five-year tax loss carryforward limit under Finance Act 2025 (KPMG) More
Malta: Gearing up for crypto asset tax reporting requirements in 2026 (Deloitte) More
Netherlands: Tax Administration clarifies correction of pre-Pillar 2 tax charges under minimum tax Act 2024 (Regfollower) More
Sri Lanka: Postponed implementation of new VAT invoice format (KPMG) More
Switzerland: Tax authority practices relating to business restructurings and DEMPE functions (David Zářecký on LinkedIn) More
Turkey: Government extends through 2030 availability of temporary Article 67 on taxation of marketable securities and derivatives (EY) More
UK: HMRC publishes draft guidance on advance tax certainty for major projects service (Deloitte) More
UK: HMRC updates to Capital Gains Manual (Deloitte) More

Monday, December 15

Global: Remote work and permanent establishment after the 2025 Update to the OECD Model Convention (Geoffroy Galéa on LinkedIn) More
Australia: Proposed changes to transfer pricing guidance for inbound distributors (KPMG) More
Canada: Canada Border Security Agency invites feedback on 2023 revisions to Valuation for Duty Regulations (EY) More
China: Frequently Asked Questions in VAT management in China (Dezan Shira and Associates) More
EU: Opinion Statement on technical simplification of EU’s Anti-Tax Avoidance Directive (ATAD) (CFE Tax Advisers Europe) More
EU: Second evaluation of the EU Directive on Administrative Cooperation in Taxation (DAC) (PwC) More
India: Dividend distribution tax cannot exceed tax treaty rate (High Court decision) (KPMG) More
Ireland: Government publishes Phase One Feedback Statement for reform of Ireland's taxation regime for interest (EY) More
Israel: Expansion of mandatory e-invoicing model (KPMG) More
Malaysia: Tax developments summary (December 2025) (KPMG) More
Serbia: Amendments to VAT law adopted (KPMG) More
US: Final and proposed regulations: Income of non-U.S. governments and of international organizations under section 892 (KPMG) More
US: IRS issues 2025 transition relief and hints at future tips and overtime information reporting obligations (Baker McKenzie) More
US: REIT PLR addresses EV charging stations, amenities, storage facility services (PwC) More
US: Report on recent US international tax developments — 12 December 2025 (EY) More
US: State tax matters (Deloitte) More
US: Treasury releases final and proposed regulations on taxing the income of foreign governments from investments in the United States (PwC) More

Friday, December 12

Global: After-Tax KPIs: A SVP of Tax’s perspective (PwC podcast, 44:33) More
Global: Status of “side-by-side” GloBE negotiations (Dragoș Dăncău on LinkedIn) More
Global: Why AI is poised to make managing tax risk and controversy easier (EY) More
France: France strengthens transfer pricing rules under 2024 Finance Act (Regfollower) More
Greece: New super-deduction tax incentives for defence sectors and manufacturing of vehicles, aircraft (KPMG) More
India: “At-cost” transfer pricing model upheld for provision of technical services in oil and gas operations (tribunal decision) (KPMG) More
Ireland: Consultation on modernisation of Professional Services Withholding Tax (PSWT) and Relevant Contracts Tax (RCT), expansion of withholding tax to platform economy, and introduction of personalised deduction rates to new modernised withholding tax regime for self-employed workers (Tax authorities) More
Kenya: High Court rules that valid objection to tax assessment must be filed on iTax system (EY) More
Kenya: Kenya Revenue Authority to validate income and expenses in income tax returns (EY) More
Switzerland: Federal Council consults on VAT amendments (Regfollower) More
UAE: Administrative Exceptions VAT Guide (Tax authorities) More
UK: Tax measures in Finance Bill 2025-2026 (KPMG) More
US: Notice 2025-78: Guidance on FDDEI exclusions under section 250 following OBBBA (Deloitte) More

Thursday, December 11

Argentina: ARCA consults on draft transfer pricing regulation (Regfollower) More
Australia: Draft Practical Compliance Guideline: Transfer pricing issues related to inbound distribution arrangements (Tax authorities) More
Bahrain: Tax authorities release updated guidance on GloBE rules (Tax authorities) More
Colombia: Senate rejects proposed tax reform bill (KPMG) More
Estonia: Estonia did not approve the proposed amendments to the minimum tax rules (Government statement) More
France: Administrative Supreme Court rules that losses must be offset on a FIFO basis (Deloitte) More
France: Tax authority issues guidance on Pillar 2 global minimum tax (Regfollower) More
Oman: E-invoicing FAQs (Tax authorities) More
Saudi Arabia: Saudi Arabia amends its integrated customs tariff schedule (EY) More
Serbia: New green taxes effective January 1, 2026 (KPMG) More
Switzerland: A global survey on the application of the control of risk and DEMPE frameworks: Switzerland (KPMG) More
Switzerland: Proposal to expand VAT platform taxation rules to digital services (KPMG) More
Taiwan: Ministry of Finance clarifies business tax inclusive pricing (Regfollower) More
UAE: Ministry of Finance to implement VAT law amendments starting January 2026 (Tax authorities) More
UK: Government pushes Pillar One implementation to 2027 (Regfollower) More
US: Final regulations on corporate stock buyback excise tax: Overview (Deloitte) More
US: Final stock repurchase excise tax regulations retroactively pare back rules (PwC) More
US: Highlights of Treasury guidance on OBBBA international tax items (PwC) More
US: Proposed regulations would source borrow fees to the residence of the recipient (Baker McKenzie) More

Wednesday, December 10

Australia: Weekly tax round-up (Deloitte) More
Canada: Canada announces new trade measures for steel imports (EY) More
Canada: Offshore Tax Havens: an intriguing problem for Canadian tax law (Jinyan Li and Angelo Nikolakakis) More
Costa Rica: MoF announces 2026 corporate tax rates (Regfollower) More
Czech Republic: Changes in R&D allowances effective January 1, 2026 (KPMG) More
Czech Republic: Comments on case concerning transfer pricing treatment of business restructuring (David Zářecký on LinkedIn) More
Czech Republic: Documentation requirements for tax-deductible depreciation of real estate improvements (Supreme Administrative Court decision) (KPMG) More
Germany: German cash pool participants in the focus of legislators and tax authorities (KPMG) More
Germany: Obligation to disclose emails in tax audits (court decision) (KPMG) More
Honduras: Honduras publishes “Guide on Country-by-Country Reporting (CbCR) Frequently Asked Questions” (EY) More
India: Physical presence required for service PE under India-Singapore treaty (Clifford Chance case: court decision) (KPMG) More
Malaysia: Updated guidelines on e-invoicing (Tax authorities) More
Nigeria: Tax Appeal Tribunal affirms authority to grant interim and interlocutory reliefs in tax disputes (KPMG) More
Poland: Parliament adopts 2026 Budget Act, increases bank tax rates (Regfollower) More
Singapore: IRAS expands GloBE guidance with comprehensive new e-learning modules (Regfollower) More
Spain: Spanish Supreme Court opens door for non-residents to apply the joint personal income tax-wealth tax limit – Major refund opportunity (Baker McKenzie) More
UAE: MoF issues new resolution outlining fines for electronic invoicing non-compliance (Regfollower) More
UAE: MoF publishes domestic minimum top-up tax guidance, FAQs (Regfollower) More
Uganda: Comments on Translink case: fees for technical or consultancy services vs. independent personal services in Uganda / UK double tax treaty (Lucas de Lima Carvalho on LinkedIn) More
US: District court upholds economic substance of intercompany transactions in Perrigo (Baker McKenzie) More

Tuesday, December 9

Global: Global e–invoicing developments tracker (3 December 2025) (EY) More
Global: Global tax talk – tax in 60 seconds (Will Morris on LinkedIn) More
Global: More jurisdictions commit to automatic exchange of information, new reports released (Deloitte) More
Global: OECD under growing pressure on Pillar Two (PwC video, 7:33) More
Global: Tax trends and developments for MNEs in 2026 (Loyens & Loeff) More
Argentina: Argentina allows exporters to convert and display tax credit balances and export refunds in US dollars (EY) More
Australia: ATO administrative approach to public country-by-country reporting exemptions (KPMG) More
Australia: ATO Top 500 findings report: Years of "justified trust" methodology, private groups (Deloitte) More
Australia: Pre-capital gains tax status can be retained when shares are held through discretionary trust (Administrative Review Tribunal decision) (KPMG) More
Belgium: Belgium announces e-invoicing tolerance period and new draft law on B2B e-invoicing mandate (EY) More
Bosnia and Herzegovina: Updated withholding tax obligations and forms (KPMG) More
Cameroon: Significant economic presence standard introduced from 2026 (KPMG) More
Estonia: Significant tax changes in Estonia from 2026 (EY) More
EU: Transfer pricing implications of CJEU judgment on application of VAT to cross-border intra-group services (KPMG) More
France: Judgment of the Paris Administrative Court on MAP access (Rhys Bane on LinkedIn) More
Malaysia: Stamp assessment and payment system replaced by e-Duti Setem starting January 1, 2026 (KPMG) More
Slovakia: Slovakia revises financial transaction tax law, exempts self-employed individuals (Regfollower) More
Taiwan: CFC current year taxable profits – deductibility of pre-CFC losses (Government) More
Taiwan: Southern National Taxation Bureau outlines tax treaty relief for overseas e-commerce operators (Regfollower) More
UAE: New Federal Decree-Laws amending the VAT Law and Tax Procedures Law (Baker McKenzie) More
UK: Finance (No. 2) Bill (Government) More
UK: Parliament considers Finance Bill containing 2025 budget proposals More
Uruguay: Parliament modifies budget bill to clarify entry into force of the Qualified Minimum Domestic Top-Up Tax (EY) More
US: Enhanced health care tax credit set to expire on 31 December 2025 (Deloitte) More
US: IRS clarifies Trump accounts and international rules under OBBBA (Deloitte) More
US: House taxwriting committee leader urges swift action on G7, Pillar Two plan (Deloitte) More
Uzbekistan: Uzbekistan outlines 2026–28 budget and fiscal plan, proposes higher corporate income tax (Regfollower) More
Vietnam: Circular 99: What Vietnam’s new accounting regime means for IFRS alignment (Dezan Shira and Associates) More

Monday, December 8

Global: 2025 update to OECD model treaty (OECD) More
Global: OECD's Global Forum 2025 Annual Report (OECD) More
Australia: Sample #1 of GloBE rules return form (Tax authorities) More
Australia: Sample #2 of GloBE rules return form (Tax authorities) More
EU: Exemption of inbound dividends from non-corporate taxes under the Parent-Subsidiary Directive – Opinion Statement on decision of CJEU in Cases C-92/24 to C-94/24, Banca Mediolanum (CFE Tax Advisers Europe) More
France: Second guidance on GloBE rules (in French) (Tax authorities) More
Greece: Legislation allowing 200% deduction for investments in defence and related manufacturing units (in Greek) (Government) More
Hungary: Proposed amendments to transfer pricing documentation requirements (in Hungarian) (Government) More
India: Netflix case (Transfer pricing – limited risk distributor or entrepreneur?) (Tribunal decision) More
Ireland: Updated guidance on hybrid mismatch rules for partnerships (Tax authorities) More
Netherlands: Decree on tax treatment of funds for joint account (FGR) and “transparent funds” (in Dutch) (Government) More
Sweden: Legislation amending interest deduction limitation rules (in Swedish) (Government) More
UK: Policy paper on proposed changes to transfer pricing, permanent establishment, and Diverted Profits Tax rules (Government) More
UK and US: US agrees to remove tariffs on UK-origin pharmaceuticals, pharmaceutical ingredients, and medical technology (Government) More
US: Notice 2025-75: section 70354(c)(2) of OBBBA (Tax authorities) More
US: Notice 2025-77: section 70312 of OBBBA (Tax authorities) More
US: Notice 2025-78: section 70322 OBBBA (Tax authorities) More

Saturday, December 6

Global: AI is already here (CIAT) More
Global: OECD 2025 Update to the OECD Model Tax Convention — key highlights (EY) More
Global: Pillar Two Side-by-Side challenges of EU law, global tax governance, sovereignty. Comments for a rational win-win path forward (William Byrnes and Pramod Kumar Siva) More
Australia: ATO releases sample forms for global and domestic minimum tax filings (Regfollower) More
Australia: Beneficial ownership, instant asset write-off bill receives Royal Assent (KPMG) More
Belgium: Draft law confirms e-invoicing grace period and clarifies the scope of mandate for non-residents (KPMG) More
China: China monthly tax brief: November 2025 (Dezan Shira and Associates) More
Estonia and EU: Estonia: Implementation of the minimum tax must be flexible and thoroughly assessed – includes Estonia’s letter to the European Commission (Government) More
Estonia and EU: Finance Minister urges EU flexibility on minimum tax (Regfollower) More
France: Tax authorities issue second guidance on Pillar 2 global minimum tax (Regfollower) More
Italy: Revenue Agency updated VAT exemption for SMEs across EU borders (Regfollower) More
Kenya: High Court determines that digital platforms are liable for VAT on full customer charges (EY) More
Korea: National Assembly approves corporate tax hike in new budget plan (Regfollower) More
Latin America: Latin American tax news - November 2025 (Joaquin Kersman on LinkedIn) More
Montenegro: Draft domestic minimum top-up tax published (in Croatian) (Government) More
Slovakia: Amendment to Financial Transaction Tax Act introduces new rules (KPMG) More
UAE: Ministry of Finance publishes Cabinet Decision on penalties for noncompliance with e-invoicing (EY) More
UK: Finance Bill reforms to transfer pricing, permanent establishments, DPT legislation (Deloitte) More
UK: HMRC has just updated its guidance on searching for comparables and arm’s length range (Borys Ulanenko on LinkedIn) More
UK: New HMRC reward scheme for whistleblowers introduced (Macfarlanes) More
UK: Primary legislation to charge NICs on salary-sacrificed pensions contributions issued (Deloitte) More
US: Digital Advertising Services Taxes: States catch up and look ahead (Deloitte) More
US: FTC disallowance guidance under section 960(d)(4) related to section 951A PTEP (Deloitte) More
US: Guidance on allocation of foreign income taxes and section 987 transition rules (Notice 2025-72) (KPMG) More
US: Report on recent US international tax developments - 5 December 2025 (EY) More
US: State tax matters (Deloitte) More

Friday, December 5

Global: How countries stack up in OECD’s 2024 APA Statistics Report (KPMG) More
Global: Seven essential actions to strengthen your global Pillar Two readiness (EY) More
Australia: Australia publishes Pillar Two compliance and administrative guidance - first returns due by 30 June 2026 (EY) More
Australia: Sample combined Pillar Two return forms (KPMG) More
Belgium: Grace period for mandatory B2B invoicing announced for certain businesses (Deloitte) More
Belgium: Three-month grace period for mandatory B2B e-invoicing (Loyens & Loeff) More
Bulgaria: Government withdraws 2026 draft budget law amid protests (Regfollower) More
Canada, Mexico, and US: USTR request for comments on United States-Mexico-Canada Agreement (USMCA) automotive goods trade (KPMG) More
Chile: SII implements new compliance requirements for digital platform operators, payment service providers (Regfollower) More
EU: Triangulation simplification applies beyond three parties in EU VAT supply chains (European General Court decision) (KPMG) More
Germany and US: German tax authorities update view on reduced WHT rates under Germany / US tax treaty (Deloitte) More
Hungary: Proposed changes to transfer pricing documentation and data disclosure (KPMG) More
Lithuania: Amendments to corporate income tax, VAT, excise taxes, and real estate tax, introduction of insurance premium tax (KPMG) More
Netherlands: Updated Dutch Fund Decree: Key updates for limited partnerships and investment funds (Norton Rose Fulbright) More
Nigeria: Guidance on withholding tax on interest from short-term securities; duty-free threshold for low-value imports; tax administration reform (KPMG) More
US: Companies using PPI indexes to compute inflation for LIFO inventory should consider taking action before year-end (PwC) More
US: Notices 2025-75, 2025-77, and 2025-78: Intent to issue proposed regulations regarding various international tax provisions of OBBBA (KPMG) More
US: Treasury releases three international tax notices related to tax act enactment (PwC) More

Thursday, December 4

Global: 5 layers of a transfer pricing audit (Borys Ulanenko on LinkedIn) More
Global: Telecommuting and taxes (Alex Parker) More
Global: Trade talking points (EY) More
Argentina: Solidarity contribution: Income tax deductibility and repetition claim explained (Baker McKenzie) More
Belgium: Three-month tolerance period for e-invoicing mandate effective January 1, 2026 (KPMG) More
Bulgaria: Government announces withdrawal of Budget laws 2026 from parliament (in Bulgarian) (Government) More
Canada: Beneficial ownership – legal substance – Husky Energy files application for leave to appeal to Supreme Court (Kevin Kelly on LinkedIn) More
Chile: Tax compliance confirmation process for platforms and payment service providers (KPMG) More
EU: E-News from KPMG’s EU Tax Centre (KPMG) More
EU: Estonia proposes that the EU consider 3 options for the EU’s GloBE Directive (Jason Hoerner on LinkedIn) More
EU: Proportionality stricto sensu and the need for an autonomous EU rule-of-law review in direct taxation (Dennis Weber) More
Hungary: Hungary consults on overhaul of transfer pricing documentation rules (Regfollower) More
India and Qatar: Income tax treaty between India and Qatar enters into force (KPMG) More
Ireland: Irish Revenue updates guidance on anti-hybrid rules for partnerships (Regfollower) More
Italy: De Grisogono case #1 – transfer pricing – CUP vs. TNMM (Supreme Court) (in Italian) (TPcases) More
Italy: De Grisogono case #2 – transfer pricing – limited risk distributor – application of TNMM (Supreme Court) (in Italian) (TPcases) More
Korea and US: US tariff modifications on products from Korea (KPMG) More
Malawi: MoF presents 2025-26 mid-year budget review, to introduce Minimum Alternate Tax (Regfollower) More
Netherlands: Updated Fund Decree – latest on Dutch tax classification as FGR for Dutch and non-Dutch limited partnerships (Loyens & Loeff) More
Poland: Legislation passed by upper house of Parliament includes direct and indirect tax changes (including simplifying tax regulations on accelerated depreciation) (KPMG) More
Poland: Summaries of recent Supreme Administrative Court decisions: (1) management fees not eligible for tax exemption; and (2) residential building not subject to property tax rate for premises used for business purposes (KPMG) More
Portugal: CJEU rules Portuguese withholding tax partially incompatible with EU law (Deloitte) More
Russia: Russia simplifies tax registration for foreign companies (Regfollower) More
Singapore: Singapore’s Amount B initiative (David Zářecký on LinkedIn) More
Turkey: Revenue Administration extends Domestic Minimum Top-Up Tax returns (Regfollower) More
UK: Government announces mandatory e-invoicing will go live with effect from April 2029 (EY) More
UK: Pillar Two – UK realities (PwC podcast, 30:28) More
US: 2025 State R&D credit changes (KPMG) More
US: Navigating the shift: The AI edge in indirect SALT—accuracy, speed, strategic insight (PwC) More
US: Notice 2025-72 provides guidance on allocating foreign taxes (Deloitte) More

Wednesday, December 3

Global: 2025 transfer pricing year in review (KPMG) More
Global: Global e–invoicing developments tracker (26 November 2025) (EY) More
Global: International tax news (November 2025) (PwC) More
Global: Most transfer pricing local files are built the wrong way around (Borys Ulanenko) More
Global: Peer review of the Automatic Exchange of Financial Account Information 2025 update (OECD) More
Global: Public consultation on tax issues relevant to global mobility of individuals (KPMG) More
Global: The New Tax Order: Evolving tax policy is rewriting the rules of business success (PwC) More
Argentina: Argentina proposes amendments to its transfer pricing regime (EY) More
Argentina: Recent indirect tax developments (KPMG) More
Canada: 2025 budget implementation bill no. 1 introduced in House of Commons (EY) More
China: Unlocking China’s new VAT law: Key changes, business impacts, and compliance tips (Dezan Shira and Associates) More
EU: CJEU judgment on compatibility with EU law of evidentiary requirements for non-resident pension funds seeking withholding tax exemption (KPMG) More
EU: CJEU rejects appeal from General Court decision that Madeira Free Zone scheme not implemented in line with approved conditions (KPMG) More
EU: EU revises Generalised Scheme of Preferences (GSP) (KPMG) More
Greece: Super-deduction regime to support investment in defence-related and allied manufacturing units (KPMG) More
Indonesia: Tax incentives for employees in labor-intensive industries, domestic holiday flights (Deloitte) More
Kenya: High Court rules that government's objection decision sent to wrong email was ineffective (EY) More
Latvia: Partial implementation of reporting obligations for cryptoasset service providers (DAC8) (KPMG) More
Philippines: Statement on the immediate and temporary suspension of all Bureau of Internal Revenue field audits and related operations (Government) More
Sweden: Parliament approves amendments to interest deduction limitation rules (KPMG) More
Turkey: Government extends Qualified Domestic Minimum Top-Up Tax filing and payment deadlines and releases QDMTT return format for testing (EY) More
UK: UK introduces Budget 2025 (EY) More
UK and US: US and UK strike agreement for tariff-free pharmaceuticals (Regfollower) More
US: Treasury redeems complex proposed excise tax regulations (Alvarez & Marsal) More

Tuesday, December 2

Global: GloBE rules require MNEs to remove the effects of “pushdown” purchase price accounting (PPA) adjustments from their numbers (Leonard Wagenaar on LinkedIn) More
Global: Most transfer pricing teams still live in step 5 of this picture: documentation (Borys Ulanenko on LinkedIn) More
Global: OECD Tax Certainty Day 2025 - consolidated information on mutual agreement procedures 2025 (Rhys Bane on LinkedIn) More
Global: OECD’s 2025 Model Tax Convention update: What it means for multinationals (DLA Piper) More
Australia: Beneficial ownership, instant asset write-off bill passes parliament (KPMG) More
Australia: Practical compliance guideline: Global and domestic minimum tax lodgment obligations - transitional approach (Tax authorities) More
Brazil: Law 15,270/2025 enacted to tax dividends and amend personal income tax rules (Baker McKenzie) More
Cyprus and US: Cyprus tax authorities issue clarification note regarding bilateral agreement with United States (EY) More
Hong Kong: Management fees paid to BVI affiliate not deductible (Court of Appeal decision) (KPMG) More
Hungary: Autumn tax package adopted, including changes to global minimum tax rules (KPMG) More
India: Taxpayer allowed foreign tax credits on income not taxable under Japan treaty (tribunal decision) (KPMG) More
Italy: Italy's permanent establishment concept affected by OECD 2025 Model Tax Convention update (EY) More
Netherlands: 2026 Tax Plan adopted by lower house of Parliament, including Pillar Two changes and implementation of DAC9 (KPMG) More
Oman: Draft data dictionary for e-invoicing (KPMG) More
Sri Lanka: Proposed amendments to tax incentives and exemptions (Colombo Port City) (KPMG) More
Switzerland: Swiss voters reject federal inheritance tax initiative (Baker McKenzie) More
Switzerland: Voters reject 50% inheritance and gift tax proposal (Deloitte) More
US: Dispute prevention and resolution options: prefiling update (KPMG) More
US: Transfer pricing landscape shifts amid IRS changes and tariffs (Grant Thornton) More
US: Understanding the 2025 Perrigo decision through the lens of a craps game (William Byrnes) More
Vietnam: Vietnam VAT rates and applicability in 2025: a brief guide (Dezan Shira and Associates) More
Zimbabwe: Direct and indirect tax proposals in 2026 budget (KPMG) More
Zimbabwe: Government announces 2026 budget, proposes digital services withholding tax (Regfollower) More

Monday, December 1

Global: Consultation document on global mobility of individuals (OECD) More
Global: Corporate Tax Statistics: report and related documents (OECD) More
Global: Report on ways to simplify taxation of cross-border business activities (OECD) More
Australia: Announcement on reportable tax position schedule (Tax authorities) More
Australia: Consultation paper on proposed News Bargaining incentive (Government) More
Cambodia: Announcement on capital gains tax (in Khmer) (Government) More
EU: Press release on evaluation of DAC (European Commission) More
EU: Report on evaluation of DAC (European Commission) More
EU: Working paper on VAT treatment of free-of-charge access to platform in exchange for user data (European Commission) More
India: Notification for transfer pricing tolerance range (Tax authorities) More
Ireland: Guidance on application of VAT grouping rules (Tax authorities) More
Japan: Guidance on consumption tax relating to satellite launch transportation services (in Japanese) (Tax authorities) More
New Zealand: Uber test case on whether Uber drivers are employees or independent contractors (Court decision) More
Portugal: Guidance on new VAT group regime (in Portuguese) (Tax authorities) More
UK: HMRC urges large businesses to review management expenses (Chartered Institute of Taxation) More
US: Final regulations on excise tax on stock repurchases (Government) More
US: Notice 2025-72 on repeal of one-month deferral election under section 898(c)(2) (Tax authorities) More

Saturday, November 29

Global: Good vs. bad transfer pricing (Borys Ulanenko on LinkedIn) More
Global: Treatment of equity accounted affiliates in GloBE rules (Chester Wee on LinkedIn) More
Australia: ATO issues guidance on Pillar 2 filing obligations (Regfollower) More
Australia: Monthly tax update (December 2025) (PwC) More
EU: Commission publishes second evaluation of administrative cooperation directive (Deloitte) More
Hong Kong: Employee fringe benefits: Tax treatment and reporting obligations (Deloitte) More
Netherlands: Dutch tax classification of (non-)Dutch limited partnerships – current state of play (Loyens & Loeff) More
Taiwan: Draft amendments to investment tax credit regulations announced (Deloitte) More
Taiwan: Tax Bureau clarifies CFC investment income deductions (Regfollower) More
UK: Autumn Budget 2025: business tax perspective (Macfarlanes) More
UK: Government releases 2025 budget, mandates VAT e-invoicing from 2029 (Regfollower) More
UK: UK retains SME transfer pricing exemption, plans new multinational reporting regime (Regfollower) More
Vietnam: Summary of recent key tax legislative developments, November 2025 (Deloitte) More

Friday, November 28

Global: Transfer pricing – PERCENTILE.INC vs PERCENTILE.EXC in Excel: Same data, different quartiles (Borys Ulanenko on LinkedIn) More
Australia: Australia extends CbC reporting deadline (Regfollower) More
Indonesia: New import framework brings greater clarity for importers (Baker McKenzie) More
Luxembourg: New circular modifies VAT treatment of company cars and repeals prior guidance (Deloitte) More
Philippines: BIR commissioner suspends field audits, related field operations, Letters Of Authority (LOA) and Mission Order (MO) issuances (Baker McKenzie) More
Singapore: IRAS releases eighth edition of transfer pricing guidelines (Deloitte) More
UK: Autumn Budget 2025 (Baker McKenzie) More
UK: Autumn Budget 2025: balancing the books for energy and infrastructure investment (Slaughter and May) More
UK: Autumn budget 2025 — Key business tax highlights (Baker McKenzie) More
UK: Autumn Budget 2025: measures to close the tax gap (Macfarlanes) More
UK: Autumn Budget 2025: UK Listing Relief for Stamp Duty Reserve Tax (Slaughter and May) More
UK: Key tax highlights of Autumn Budget 2025 (Deloitte) More
UK: Transfer pricing – interquartile range (David Zářecký on LinkedIn) More

Thursday, November 27

Global: Comments invited on tax issues relating to global mobility of individuals (Deloitte) More
Global: Public consultation document: Global mobility of individuals (OECD) More
Global: Report on recent US international tax developments (EY) More
Global: Report to G20 leaders on international tax cooperation, G20 leaders’ declaration on Pillar Two (KPMG) More
Global: Shaping a fair and consistent tax order in a fragmented world: between realism and ambition (Chiomenti) More
Global: We asked experienced TP practitioners how they handle loss-making comparables (Borys Ulanenko on LinkedIn) More
China and US: USTR extends product exclusions related to China section 301 tariffs (KPMG) More
Germany: Amendments to Pillar Two rules passed by lower house of parliament; draft DAC9 legislation submitted to upper house of parliament (KPMG) More
Germany, Ireland, Italy, Luxembourg, Netherlands, Portugal, and UK: Private equity tax updates: hot topics Q3 & Q4 2025 (EY) More
Ghana: Finance minister presents 2026 budget statement and economic policy (EY) More
Mauritius: VAT applies on digital and electronic services by foreign suppliers from January 2026 (Deloitte) More
Mexico: Reforms to customs law (KPMG) More
Russia: State Duma approves 2026 tax code amendments (Regfollower) More
Singapore: Updated transfer pricing guidelines include pilot implementation of Pillar Two Amount B (KPMG) More
UK: Autumn Budget 2025 (PwC) More
UK: Budget 2025: Reforming for growth? Our quick round-up of the key tax measures in the Autumn Budget (KPMG) More
UK: Budget 2025 tax related documents (Government) More
UK: Smorgasbord not showstopper: the UK Budget 2025 (Slaughter and May) More
US: Realigning year-end planning considerations after the One Big Beautiful Bill Act (PwC) More
US: Treasury releases guidance addressing the repeal of Section 898(c)(2) and the recognition of Section 987 pretransition gain or loss (PwC) More

Wednesday, November 26

Global: 2025 edition of Corporate Tax Statistics released (Deloitte) More
Global: G20 Leaders' Declaration reflects continued engagement to address Pillar Two concerns (EY) More
Global: OECD issues 2025 Model Tax Convention update: new Commentary on cross-border working and other issues (PwC) More
Global: OECD releases update to Model Tax Convention (EY) More
Global: Pillar Two in practice: Seven lessons from the front lines of compliance (Deloitte) More
Global: The dirty secret of transfer pricing: we mostly don’t design models, we rationalize bad facts (Borys Ulanenko on LinkedIn) More
Australia: Consultation on operation of 2018 GST reforms (KPMG) More
Australia: Weekly tax round-up (Deloitte) More
Belgium: Tax measures in budget framework 2026-2029 (KPMG) More
Brazil: Dividend withholding tax and refund mechanism for foreign investors (KPMG) More
EU: CJEU referral (from Netherlands) on whether sale of real property qualifies as transfer of going concern for VAT purposes (KPMG) More
EU: ECOFIN fails to agree on revisions to energy tax directive (Deloitte) More
France: National Assembly rejects first part of 2026 Finance Bill (Regfollower) More
Italy: The proposed Italian taxation of portfolio dividends and the principle of non-(reverse) discrimination (BonelliErede) More
Sweden: Parliament adopts amendments to interest deduction rules (Regfollower) More
UK: Guidance on cryptoasset reporting framework (CARF) (KPMG) More
US: Notice 2025-72: Intent to issue proposed regulations on repeal under OBBBA of one-month deferral election under section 898(c)(2) (KPMG) More
US: OB3 Curveballs: Federal Tax interplay and State Tax conformity (PwC podcast, 33:15) More
US: The IRS's blocked income regulations are themselves blocked (William Byrnes) More
US: US State income tax digest: Highlighting significant income and business tax developments (PwC) More

Tuesday, November 25

Global: Comments on use of interquartile range in transfer pricing (Borys Ulanenko on LinkedIn) More
Global: Global tax talk – tax in 60 seconds (Will Morris on LinkedIn) More
Global: November 2025 update on international tax cooperation delivered to G20 leaders (Deloitte) More
Global: OECD issues 2025 update to the OECD Model Tax Convention including guidance on remote work arrangements (Baker McKenzie) More
Global: OECD Tax Certainty Day 2025 - MAP & APA statistics (Rhys Bane on LinkedIn) More
Global: OECD TPG on contractual assumption of risk (Paul Sutton on LinkedIn) More
Global: OECD – Updates to fixed place of business in remote work (KPMG) More
Africa: Global minimum tax design creates five key challenges for Africa (KPMG) More
Brazil: Superior Court of Justice allows interest on net equity (INE) deductions related to prior fiscal years (Deloitte) More
Colombia: Proposed implementation of OECD cryptoasset reporting framework (CARF) (KPMG) More
EU: Beneficial ownership continues to confuse, especially in an EU context. But is it really that bad? (Leonard Wagenaar on LinkedIn) More
EU: E-News from KPMG’s EU Tax Centre (KPMG) More
EU: European Commission publishes report on the evaluation of the DAC (KPMG) More
EU: European Commission publishes second evaluation of the Directive on Administrative Cooperation in Taxation (DAC) (Loyens & Loeff) More
India: Deduction of payments for intercompany advisory and business support services allowed (High Court decision) (KPMG) More
Ireland: Feedback statement for Phase One of Reform of Ireland’s Taxation Regime for Interest (Government) More
Israel: Comments on Hexadite transfer pricing case (David Zářecký on LinkedIn) More
Lithuania: Tax authorities approve long term corporate tax incentives (Regfollower) More
Romania: Proposed logistics tax on certain goods from outside EU (KPMG) More
Singapore: IRAS revises transfer pricing rules, launches pilot SSA (i.e., Amount B) for baseline routine marketing and distribution activities (Regfollower) More
Sweden: Parliament approves amendments to interest deduction rules to comply with EU law (in Swedish) (Government) More
UAE: Taxpayer user manual – corporate tax payments (Tax authorities) More
UAE: UAE completes first corporate tax compliance cycle: Key insights for future readiness (EY) More
US: IRS provides 2025 penalty relief for reporting on qualified tips and overtime (PwC) More

Monday, November 24

Global: 2025 Update to the OECD Model Tax Convention - global mobility and beyond (Alvarez & Marsal) More
Global: When your remote worker PE is also your P2 eligible employee (Priscilla Koh on LinkedIn) More
Australia: Super funds, collective investment vehicles required to complete reportable tax position schedule for 2026 (KPMG) More
Brazil and US: US revises tariffs on Brazilian imports, exempts certain agricultural products (KPMG) More
Greece: VAT suspension on real estate extended to December 31, 2026 (KPMG) More
Kenya: Draft regulations proposing new framework for advance pricing agreements (APAs) (KPMG) More
Kenya: Kenya High Court rules commissions received by payment service provider were VAT exempt (EY) More
Kenya: Tax Appeals Tribunal rules switching services offered by payment service providers are VAT exempt (EY) More
Mauritius: Fair share contribution payment and filing obligations clarified by tax authority (Deloitte) More
Mauritius: QDMTT effective dates and notification deadlines clarified by tax authority (Deloitte) More
Netherlands: Dutch Supreme Court sends VAT case for property transfers to CJEU (Loyens & Loeff) More
Portugal: Standard corporate income tax rate reduced (Deloitte) More
Portugal: VAT group regime clarified (Deloitte) More
US: Final regulations: Guidance on 1% excise tax on repurchases of corporate stock (KPMG) More
US: Final regulations on corporate stock buyback excise tax released (Deloitte) More
US: Guidance on OBBBA’s tipped income, overtime compensation, and rural loans issued (Deloitte) More
US: Report on recent US international tax developments (EY) More
US: State tax matters (Deloitte) More
US: Tariffs and Advance Pricing Agreements (KPMG) More
US: Treasury issues final regulations on stock repurchase excise tax (PwC) More

Friday, November 21

Global: 2025 Update to the OECD Model Tax Convention: overview of key changes (Chiomenti) More
Global: OECD model tax treaty update: New guidance on remote working permanent establishments (Deloitte) More
Global: OECD report considers ways to simplify taxation of cross-border business activities (Deloitte) More
Global: Remote work, PEs, and the OECD (Lucas de Lima Carvalho) More
Global: Tax inspector: “Your cost-plus mark-up is minus 2%. Please explain.” (Borys Ulanenko on LinkedIn) More
Australia: Judicial developments in the taxation of non-resident investors in Australia (Deloitte) More
Belgium: Retroactive amendments to lump sum allowances for foreign business trips (Deloitte) More
Colombia: New customs regime proposed (KPMG) More
EU: European Commission publishes follow-up assessment of directive on administrative cooperation (DAC) (Regfollower) More
EU: Law professors file amicus curiae brief in ECJ case on whether the UTPR (in the EU GloBE Directive) conflicts with EU law (Amicus curiae brief) More
Ireland: Guidance on application of VAT grouping rules (KPMG) More
Israel: Ministry of Finance publishes draft legislation for implementing Qualified Domestic Minimum Top-up Tax (EY) More
Italy: Filing and payment obligations for Pillar Two top-up tax (KPMG) More
Poland: Parliament extends withholding tax exemption for foreign investors, aligns law with EU rules (Regfollower) More
Singapore: Singapore’s TP rules just shifted: 3 changes in the 8th edition you can’t ignore (Neil Periera on LinkedIn) More
Singapore: Tax deduction for newly issued shares used to fulfil obligations under Employee Equity-Based Remuneration (EEBR) schemes (Deloitte) More
Singapore: Transfer pricing guidelines (8th edition) (Tax authorities) More
South Africa: Proposed amendments to application of “conduit principle” in relation to trust distributions (KPMG) More
UK: Group relief surrenders of tax losses and unlawful distributions (Baker McKenzie) More
US: Branch profits tax imposed on foreign reverse hybrid may be reduced or eliminated under tax treaty (PwC) More
US: Notice 2025-71: Interim guidance on tax benefit for lenders on loans secured by rural or agricultural real property under section 139L (KPMG) More
US: Patel’s case - application of codified economic substance (section 7701(o)) (Błażej Kuźniacki on LinkedIn) More
US: Trump semiconductor tariff policy plan most likely deferred, sources say (Regfollower) More

Thursday, November 20

Global: 2025 update to OECD Model Tax Convention (KPMG) More
Global: 2025 update to OECD Model Tax Convention – executive summary (Jitendra Jain on LinkedIn) More
Global: Beyond Pillar Two: global tax policy update (PwC podcast, 37:52) More
Global: Latest on BEPS and beyond (EY) More
Global: OECD releases the 2025 Update to its Model Treaty (Loyens & Loeff) More
Global: OECD updates Model Tax Convention to reflect rise of cross-border remote work and clarify taxation of natural resources (OECD) More
Global: Report considers ways to simplify taxation of cross-border business activities (Deloitte) More
Global: Tax policy insights (October 2025) (Alvarez & Marsal) More
Global: Updated list of signatories to the GloBE Information Return (GIR) MCAA (KPMG) More
Argentina: Export rebate refund mechanisms; reduced export duties for certain oils (KPMG) More
Brazil and Netherlands: Dutch Advocate General classifies Brazilian interest on net equity payments as dividends (EY) More
Canada: DoF introduces legislation to implement 2025 budget, includes tax incentives for capital investments (Regfollower) More
EU: CJEU General Court judgment that Code of Conduct Group not covered by general presumption of confidentiality (KPMG) More
EU: European Commission report on evaluation of DAC (KPMG) More
Ghana: MoF presents 2026 budget, proposes VAT reforms (Regfollower) More
Greece: VAT Code amended to reduce certain tax burdens (Deloitte) More
Kenya: Kenya Revenue Authority publishes draft regulations on Advance Pricing Agreement framework (EY) More
Liechtenstein: Additional Pillar Two registration requirement adopted (KPMG) More
New Zealand: Income tax treatment of software development expenditure and SaaS customisation and configuration costs – public consultation (Tax authorities) More
Panama: Approval of agreement to join Mercosur (KPMG) More
Portugal: Reduction in corporate income tax rates from 20% to 17% (KPMG) More
Romania: CbCR in the spotlight: Tax authorities launch awareness campaign for voluntary compliance with 31 December 2025 deadline (EY) More
Russia: State Duma approves key tax policy bill, introduces incentives for businesses and individuals (Regfollower) More
Spain: Tax newsletter (October 2025) (Garrigues) More
UK: HMRC urged large businesses to review management expenses (Regfollower) More
UK: Transfer pricing: new HMRC guidance raises the bar for benchmarking studies (Macfarlanes) More

Wednesday, November 19

Global: 2024 OECD MAP statistics: key trends in MAP and APAs as Ireland recognised as most improved jurisdiction for APAs
(A & L Goodbody) More
Global: 2025 report on tax administration includes information on rise of AI (Deloitte) More
Global: Enhancing simplicity to foster tax certainty and growth (OECD) More
Global: GloBE rules – using sub-consolidated financial statements – transitional CbCR safe harbour (Chester Wee on LinkedIn) More
Global: Joint ventures and Pillar Two (KPMG) More
Global: Tax treaty round-up (Deloitte) More
Global: Trade lines (EY) More
Global: Your TP documentation won’t save you in an audit (Borys Ulanenko on LinkedIn) More
Australia: ATO to revise transfer pricing guidance on imported products (Regfollower) More
Belgium: Extended filing deadline for domestic minimum top-up tax (DMTT) return (KPMG) More
Czech Republic: Supreme Administrative Court issues ruling on limits of transfer pricing rules (Regfollower) More
Egypt: Egypt introduces significant updates to VAT provisions (EY) More
Ghana: Tax measures in 2026 budget (KPMG) More
India: Netflix case: Taxpayer treated as limited-risk distributor and use of transactional net margin method upheld (tribunal decision) (KPMG) More
India: Supreme Court on advocate-client privilege: imposes restrictions on summoning advocates during investigations (BMR Legal) More
Kenya: Kenya Bureau of Standards (KEBS) imposes standards levy on manufacturers (Regfollower) More
Kenya: Kenya enacts Virtual Asset Service Providers Act – a new regulatory era (EY) More
Luxembourg: Guidance clarifies VAT treatment of company cars (KPMG) More
Malta: Guidance on automatic exchange ot information (AEOI) (KPMG) More
Morocco: Government approves draft decree updating transfer pricing documentation, filing rules (Regfollower) More
Poland: Continuity of business as condition for VAT exemption (Supreme Administrative Court decision) (KPMG) More
Portugal: Indirect taxes newsletter (November 2025) (Garrigues) More
US: Essential tax and wealth planning guide: 2026 edition (Deloitte) More
US: Tax Court holds that regulations do not extend the BBA modification period (Baker McKenzie) More

Tuesday, November 18

Global: Global tax talk – tax in 60 seconds (Will Morris on LinkedIn) More
Global: How Generative AI may affect value chains and transfer pricing (KPMG) More
Global: OECD Tax Certainty Day 2025 – MAP Awards (Rhys Bane on LinkedIn) More
Global: Segmentation in transfer pricing: Re-examining the economic reality behind arm’s length margins (Ajit Jain on LinkedIn) More
Argentina, Ecuador, El Salvador, Guatemala, and US: Trump announces pending trade pacts with Argentina, Ecuador, El Salvador, and Guatemala (Deloitte) More
Argentina, Ecuador, El Salvador, Guatemala, Liechtenstein, Switzerland, and US: US announces new trade frameworks and expanded agricultural tariff exclusions (EY) More
Australia: Weekly tax round-up (Deloitte) More
Belgium: Belgian QDMTT return deadline extended to 30 June 2026 (EY) More
Brazil: Comments on Brazil’s new 10% dividend withholding tax (Lucas de Lima Carvalho on LinkedIn) More
Czech Republic: Aufeer Design case – transfer pricing – deductibility of advertising expenses (Supreme Administrative Court) (in Czech) (TPcases) More
Estonia: Estonia calls for Pillar 2 tax flexibility for small EU economies (Regfollower) More
EU: Commission paper on VAT treatment of free-of-charge access to platform in exchange for user data (KPMG) More
Greece: Guidance on application of digital transaction duty (KPMG) More
India: Comments on Indian transfer pricing case, Netflix (David Zářecký on LinkedIn) More
India: MoF clarifies transfer pricing tolerance range for FY 2025-26 (Regfollower) More
Israel: Hexadate case – transfer pricing – share acquisition, followed by sale of IP – value of sold IP (District Court) (in Hebrew) (TPcases) More
Israel: ITA circular confirms major policy shift in approach to MNEs conducting R&D activity (Deloitte) More
Japan: Overview of tax system (2025) (KPMG) More
Slovenia: Government endorses amendments to draft 2026-27 budget implementation Act, includes corporate tax increases (Regfollower) More
US: Fate of enhanced premium tax credit remains uncertain after government shutdown ends (Deloitte) More
US: From scrutiny to strategy: building a resilient intercompany services framework (PwC) More
US: IRS guidance allows trusts to keep tax status when staking digital assets (Deloitte) More
US: US removes reciprocal tariffs on certain agricultural products (KPMG) More
US: Year-end updates and tax planning for partnerships (KPMG) More

Monday, November 17

Global: 2025 report on effective carbon rates released (Deloitte) More

Argentina, Ecuador, El Salvador, Guatemala, and US: US trade agreement frameworks with Argentina, Ecuador, El Salvador, and Guatemala (KPMG) More

Brazil: The new Brazilian withholding tax on dividends (PwC) More

Canada: Canada's 2025 federal budget introduces revised transfer pricing rules (EY) More

EU: Agreement to repeal small consignments import relief (KPMG) More

Korea and US: US and Korea announce trade deal framework (KPMG) More

Liechtenstein, Switzerland, and US: White House announces framework for US trade deal with Liechtenstein and Switzerland (KPMG) More

Mexico: Various direct and indirect tax amendments; new tax benefits in Yucatán – changes affect taxation of banks and insurance companies, as well as digital tax receipts (CFDI) (KPMG) More

US: Report on recent US international tax developments (EY) More

US: State tax matters (Deloitte) More

US: US Tax Court: Taxpayer’s elections under section 172(b)(3) did not relinquish carryback of specified liability loss (KPMG) More

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