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Current News & Views

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Thursday, January 15

  • Global: Accounting, reporting implications of OECD’s Side-by-Side (PwC podcast, 14:39) More

  • Global: Giving credits where due (Alex Parker) More

  • Global: Global indirect tax news (Deloitte) More

  • Global: Global minimum tax: Understanding the Side-by-Side package – Slide deck and recording of OECD webinar (OECD) More

  • Global: OECD: Guidance on digital continuous transactional reporting (DCTR) for VAT (KPMG) More

  • Global: OECD Model Tax Convention – 2025 Update (KPMG) More

  • Global: OECD releases Pillar Two Side-by-Side package: Key tax takeaways for businesses (DLA Piper) More

  • Argentina: Argentina enacts 'Tax Innocence Law' that includes changes to criminal and procedural tax laws (EY) More

  • Canada: Canada provides guidance for steel derivative goods surtax and relief for certain steel goods (EY) More

  • Canada: Canada Revenue Agency reverses longstanding position on GST/HST status of trailing commissions (EY) More

  • China: China to abolish export VAT rebates for solar products, phase out incentives for batteries (Regfollower) More

  • EU: Carbon border adjustment mechanism (CBAM) successfully entered into force on January 1, 2026 (KPMG) More

  • Ireland: Ireland enacts Finance Act 2025, enhances R&D tax credits (Regfollower) More

  • Israel: Israel implements Qualified Domestic Minimum Top-up Tax effective beginning in 2026 (EY) More

  • Malaysia: Tax developments summary (January 2026) (KPMG) More

  • Mexico: Extension of tax incentives for border regions and fuels (KPMG) More

  • Peru: Peru extends R&D tax incentives through 2028 (Regfollower) More

  • Turkey: MoF issues guidance for domestic minimum top-up tax returns (Regfollower) More

  • Turkey: Turkey further extends Qualified Domestic Minimum Top-Up Tax filing and payment deadlines (EY) More

  • UK: Countdown to the International Controlled Transactions Schedule – how UK businesses can prepare for new transfer pricing reporting requirements (Macfarlanes) More

  • Uruguay: Ministry of Economy and Finance amends investment projects regime (EY) More

  • US: Accounting for income taxes: quarterly hot topics (January 2026) (Deloitte) More

  • US: Fourth quarter 2025 state and local tax developments (PwC) More

  • US: Interim guidance on permanent 100% additional first-year depreciation deduction under section 168(k), as reinstated by OBBBA (KPMG) More

  • US: JCT list of expiring federal tax provisions, 2025–2035 (KPMG) More

  • US: United States imposes immediate 25% tariff on certain advanced computing chips (KPMG) More

 

 

Wednesday, January 14

  • Global: E-invoicing developments tracker (as of 7 January 2026) (EY) More

  • Global: Global tax policy and controversy watch | January 2026 edition (EY) More

  • Global: Has the global minimum tax survived Trump? (Pascal Saint-Amans on LinkedIn) More

  • Global: We spent the last few months building the most comprehensive transfer pricing knowledge hub on the internet. And we're giving it away for free (Borys Ulanenko on LinkedIn) More

  • Australia: Weekly tax round-up (12 January 2026) (Deloitte) More

  • China: Tax updates – VAT Law Implementation Rules (Baker McKenzie) More

  • China and US: US to impose tariffs on Iran’s trade partners (Regfollower) More

  • EU: EC notice confirming application of Pillar Two side-by-side package under EU minimum tax directive (KPMG) More

  • EU: EU tax law: Highlights of 2025 (Loyens & Loeff) More

  • EU: Navigating the first wave of EU public country-by-country reporting (KPMG) More

  • Hungary: Decree with updated transfer pricing rules (in Hungarian) (Government) More

  • Mexico: 2026 tax reform - tax credit guarantee (Baker McKenzie) More

  • Mexico: Customs value declaration - new effective date (Baker McKenzie) More

  • Romania: Amendments to various direct and indirect taxes, new e-invoicing obligations (KPMG) More

  • US: Forthcoming proposed regulations would address the pre-OBBBA transition rule for IRC section 951(a)(2)(B) and the GILTI and FDDEI changes made by OBBBA (EY) More

 

 

Tuesday, January 13

  • Global: Comments on GloBE’s Simplified ETR Safe Harbour (Chester Wee on LinkedIn) More

  • Global: Global tax talk in 60 seconds (Will Morris on LinkedIn) More

  • Global: OECD: Design and operation of digital continuous transactional reporting (DCTR) regimes for VAT (KPMG) More

  • Global: Report released on digital continuous transactional reporting for VAT purposes (Deloitte) More

  • Global: Shipping tax update (Loyens & Loeff) More

  • Cambodia: Capital gains tax on immovable property postponed until 1 January 2027 (Deloitte) More

  • Colombia: Government adopts temporary tax measures to mitigate state of economic emergency (Deloitte) More

  • EU: European Commission publishes notice in support of Pillar Two Side-by-Side Package (KPMG) More

  • EU: European Commission recognizes OECD Pillar Two side-by-side safe harbors (Deloitte) More

  • EU: Side-by-Side as discordant constitutional element: what can EU Member States do? (Jasper Korving) More

  • France: SNA case – transfer pricing – related party distributor – whether discounts should be taken into account when performing comparability analysis (Administrative Court of Appeal decision) (in French) (TPcases) More

  • Germany: Updated guidance issued on use of OECD model commentary in tax treaty interpretation (Deloitte) More

  • Ghana: Parliament enacts several indirect tax-related laws, effective 1 January 2026 (EY) More

  • India: Tribunal rejects recharacterization of Netflix India (BMR Legal) More

  • Israel: Qualified domestic minimum top-up tax to be introduced from 2026 (Deloitte) More

  • Korea: Updated guidance on mutual agreement procedure (Tax authorities) More

  • Trinidad and Tobago: New taxes in Finance Act 2025 include commercial asset levy (KPMG) More

  • Turkey: Revenue Administration extends 0% withholding tax on bonds, lease certificates (Regfollower) More

  • US: Supreme Court to determine fate of Trump’s sweeping global tariffs on 14 January (Regfollower) More

  • US: Tariff increases on upholstered furniture, kitchen cabinets, and vanities delayed (Deloitte) More

  • US: US State income tax digest (PwC) More

  • US: What’s new in energy credits for 2026 (KPMG) More

 

 

Monday, January 12

  • Global: OECD public consultation meeting to discuss global mobility of individuals (on January 20) – registration link (OECD) More

  • Global: OECD webinar on GloBE Side-by-Side Package (on January 13) – registration link (OECD) More

  • China: VAT implementation regulations (in Chinese) (Government) More

  • EU: CBAM implementing regulation (European Commission) More

  • Hong Kong: Consultation paper on implementation of CARF and amended CRS (Government) More

  • Indonesia: Regulation on procedures for tax treaty implementation (in Bahasa Indonesia) (Government) More

  • Italy: 2026 Budget Law (in Italian) (Government) More

  • Korea: Announcement on outbound equity investments (Government) More

  • Malaysia: Updated guidance on special and double deductions for testing-related expenditure (in Bahasa Malaysia) (Tax authorities) More

  • Slovak Republic: Guidance on tax treatment of outbound software payments (in Slovak) (Tax authorities) More

  • Turkey: Presidential Decision on reduction in DST rate (in Turkish) (Government) More

  • US: FAQs on section 163(j) interest expense limitation following amendments by OBBBA (Tax authorities) More

  • US: Presidential memorandum directing US to withdraw from multiple international organisations (Government) More

  • Vietnam: Decree on imposition of tax on capital gains derived by non-resident shareholders (in Vietnamese) (Government) More

 

Saturday, January 10

  • Global: "The Functional Fallacy – The ALP and the Limits of a Conduct-Based Approach" – article by Richard Collier and Ian Dykes; comments by Paul Sutton (Paul Sutton on LinkedIn) More

  • Global: IFRS version of Q4 Quarterly Tax Developments updated through 31 December 2025 (EY) More

  • Global: Pillar Two: the Side-by-Side Package (PwC podcast, 51 mins) More

  • Cambodia: ACAR publishes deadlines to submit 2025 financial statements (Deloitte) More

  • Cyprus: Statement that Cyprus supports Inclusive Framework’s Side-by-Side Package (note: Cyprus is not a member of the Inclusive Framework) (Government) More

  • Italy: Italy makes indirect tax changes through 2026 Italian Budget Law and publishes consolidated VAT code (EY) More

  • Philippines: Thresholds for non-taxable employee de minimis benefits increased (Deloitte) More

  • Singapore: IRAS releases additional details on registration for MTT and DTT (Deloitte) More

  • Turkey: Turkey removes simplified entries for B2C e-commerce imports (EY) More

  • UK: Finance Bill (No. 2) Bill 2024-26 progress update (Deloitte) More

  • UK: HMRC publishes draft guidance on transfer pricing, PEs, and DPT reforms (Deloitte) More

  • UK: HMRC publishes guidelines for compliance on imported hybrid mismatches (Deloitte) More

  • UK: HMRC updates guidance on withholding tax on payments of interest overseas (Deloitte) More

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

  • US: State tax matters (Deloitte) More

  • US: Trade lines (EY) More

 

 

Friday, January 9

  • Global: Global tax deal's highlights and gaps (Alex Parker) More

  • Global: The Pillar 2 Side-by-Side Package: a structural breach of EU tax law (Dennis Weber) More

  • Bahrain: Updated guidance on domestic minimum top-up tax (Tax authorities) More

  • Canada: Husky Energy case – beneficial ownership – appeal to Supreme Court (Kevin Kelly on LinkedIn) More

  • Japan: 2026 Japan tax reform outline (Overview) (EY) More

  • Japan: Outline of the 2026 tax reform proposals (KPMG) More

  • Japan: Overview of 2026 tax reform proposals (PwC) More

  • Singapore: IRAS updates transfer pricing guidance, raises indicative margin for related party loans (Regfollower) More

  • Singapore: Regulations on GloBE tax provisions (Government) More

  • Tanzania: Coffee Exporters case – transfer pricing – whether unrelated purchaser is an associate for transfer pricing purposes (Court of Appeal decision) (TPcases) More

  • Tanzania: SEACOM case – transfer pricing – characterisation of financing as loan – withholding tax on deemed interest (Court of Appeal decision) (TPcases) More

  • UK: Draft guidance on new advance tax certainty service (ATCS) (KPMG) More

  • UK: Providing scientific education through digital platform does not qualify for R&D tax relief (First-tier Tribunal decision) (KPMG) More

  • UK: Stamp duty land tax general anti-avoidance rule applied to series of intra-group transactions (Court of Appeal decision) (KPMG) More

  • Uruguay: Decree providing exemption under domestic minimum top-up tax for entities covered by fiscal stability agreements (in Spanish) (Government) More

  • Vietnam: New circular on customs procedures and tax administration for import and export of goods will take effect from 1 February 2026 (KPMG) More

Thursday, January 8

  • Global: GloBE rules – Substance-based Tax Incentive Safe Harbour (Chester Wee on LinkedIn) More

  • Global: OECD Pillar Two: Side-by-side package released (updated) (Deloitte) More

  • Global: OECD publishes Pillar Two Side-by-Side System (PwC) More

  • Global: Overview of Pillar Two side-by-side package: analysis and observations (KPMG) More

  • Global: Pillar Two Simplified ETR Safe Harbour (PwC) More

  • Global: Substance-based tax incentive safe harbour for Pillar Two Groups (PwC) More

  • Argentina: Argentina updates transfer pricing penalties for noncompliance with formal obligations (EY) More

  • Belgium: Transfer pricing studies not required to be submitted with local file form (Deloitte) More

  • Brazil: Amendments to indirect tax reform adopted (KPMG) More

  • China: China monthly tax brief: December 2025 (Dezan Shira and Associates) More

  • Colombia: Government establishes temporary taxes amid State of Economic Emergency (EY) More

  • Cyprus: Cyprus enacts major tax reform legislation (EY) More

  • EU: EU Tax Alert: Recent developments for tax specialists (Loyens & Loeff) More

  • France: ArcelorMittal case – transfer pricing – intragroup royalties (Court of Appeal of Paris) (in French) (TPcases) More

  • Hungary: Hungary introduces new Transfer Pricing Decree tightening local compliance (EY) More

  • Italy: Italian Parliament approves 2026 Budget Law with tax measures affecting banks, other financial intermediaries and insurance companies (EY) More

  • Japan: 2026 tax reform proposals (English summary) (Government) More

  • Japan: 2026 tax reform proposals (Japanese summary) (Government) More

  • Japan: 2026 tax reform proposals (in Japanese) (Government) More

  • Luxembourg: Luxembourg opens Pillar Two registration (Loyens & Loeff) More

  • Mozambique: Amendments to VAT, corporate and individual income tax, excise tax, and customs laws (KPMG) More

  • US: Treatment of domestic R&E expenditures under the One Big Beautiful Bill Act—state tax and Important federal considerations (KPMG) More

  • Vietnam: Guidance on new international financial centers regime (KPMG) More

 

 

Wednesday, January 7

  • Global: Global e–invoicing developments tracker | 31 December 2025 (EY) More

  • Global: Global tax talk in 60 seconds (Will Morris on LinkedIn) More

  • Global: GloBE rules – side-by-side system (Chester Wee on LinkedIn) More

  • Global: Legal implementation of TNMM / CPM (Paul Sutton on LinkedIn) More

  • Global: New Pillar Two framework: unboxing the side-by-side package (Alvarez & Marsal) More

  • Global: OECD Pillar Two: Side-by-side package released (Deloitte) More

  • Global: OECD publishes “side-by-side” package on Pillar Two (Loyens & Loeff) More

  • Global: OECD releases side-by-side package on Pillar Two global minimum tax: First impressions (EY) More

  • Argentina: Recent indirect tax developments (KPMG) More

  • EU: EU direct tax initiatives: 2025 year-end state of play (KPMG) More

  • Korea: Korea enacts 2026 tax reform bill (EY) More

  • Latin America: Latin American tax news - December 2025 (Joaquin Kersman on LinkedIn) More

  • Malaysia: Tax changes related to stamp duty, sales and service tax, and e-invoicing (KPMG) More

  • Mexico: Miscellaneous tax resolution for FY2026 clarifies effect of 2026 tax reform on digital platforms (KPMG) More

  • Namibia: Tax proposals in 2025/2026 mid-year budget review (KPMG) More

  • Nigeria: “Certified” versions of tax reform legislation released by National Assembly – Intended to address discrepancies in legislation, but errors and gaps in legislation remain (KPMG) More

  • Portugal: Portugal abolishes regulatory clawback mechanism in energy sector (EY) More

  • Sri Lanka: Strategic Development Projects (Amendment) Act, No. 26 of 2025:  effective December 17, 2025 (KPMG) More

  • Turkey: Turkey issues final General Communique on local and global minimum top-up corporation tax (Pillar Two) (EY) More

  • Turkey: Turkey revises Digital Service Tax rate for 2026 and 2027 (EY) More

  • UAE: Federal Tax Authority issues detailed guidance on Advance Pricing Agreements (EY) More

  • US: 2026 Tax Policy Outlook: What’s on the horizon (PwC) More

  • US: OBBBA international tax guidance: what’s new, what’s looming (Alvarez & Marsal) More

 

 

Tuesday, January 6

  • Global: GloBE rules: side-by-side package (OECD) More

  • Global: GloBE rules – side-by-side package – press release (OECD) More

  • Global: OECD: Agreement reached on Pillar Two side-by-side package (KPMG) More

  • Global: OECD announces agreement on a range of new Pillar Two safe harbours (PwC) More

  • Bahrain: Draft law introducing 10% corporate income tax referred to legislative authorities; updated guide on scope of domestic minimum top-up tax (DMTT) (KPMG) More

  • Barbados: Repeal of 2019 economic substance law; passage of Economic Diversification and Growth Fund Act 2025 (KPMG) More

  • Brazil: Temporary four-month waiver of penalties for tax on goods and services and VAT invoice obligations in early 2026 (KPMG) More

  • China: New regulations unveiled, ushering in a new era for China VAT (KPMG) More

  • Colombia: Legislative Decree 1474 of 2025 – Extraordinary tax measures due to economic emergency (Baker McKenzie) More

  • Denmark: Global Services case – transfer pricing – intragroup transfer of intangibles – valuation (Tax Tribunal decision) (in Danish) (TPcases) More

  • Greece: Guidance on taxation of distribution or capitalization of untaxed profits from prior years (KPMG) More

  • India: Comments on Shell case (transfer pricing)  (David Zářecký on LinkedIn) More

  • India: Shell case – transfer pricing – production sharing contracts – intragroup services provided “at cost” – cost contribution arrangement (Income Tax Appellate Tribunal decision) (TPcases) More

  • India: Supreme Court clarifies the scope of deduction of head office expenditure for non-residents as enshrined under section 44C of the Income Tax Act, 1961 (Alvarez & Marsal) More

  • Indonesia: Indonesia issues regulation on procedures for tax treaty implementation (Martiana Sipahutar on LinkedIn) More

  • Korea: Guidelines for requesting mutual agreement procedure (MAP) assistance (Martiana Sipahutar on LinkedIn) More

  • Luxembourg: Luxembourg introduces GloBE Information Return, exchange of information and Administrative Guidance on Article 9.1 (EY) More

  • Luxembourg: Luxembourg introduces new tax credit to support investments in innovative start-ups (EY) More

  • Malaysia: Direct and indirect tax measures in Finance Act 2025 (KPMG) More

  • Malaysia: Malaysia widens capital gains tax “disposal” definition: Impact on M&A, corporate restructuring and exit planning (Alvarez & Marsal) More

  • Mexico: General foreign trade rules for 2026; amendments to import and export duties law (KPMG) More

  • Mexico: Revision of e-invoicing (CFDI) complement for digital platforms (KPMG) More

  • Singapore: Singapore Transfer Pricing Guidelines (Eighth Edition) (Alvarez & Marsal) More

  • Singapore: Updated guidance on income tax treatment of hybrid instruments (Tax authorities) More

  • Spain: Tax newsletter (November 2025) (Garrigues) More

  • UAE: Guidance on profit margin scheme (VAT) (Tax authorities) More

  • Uruguay: Executive Branch sets conditions to exclude Free Trade Zone users, forestry entities and special agreements from QMDTT payment (EY) More

  • US: Recent developments and guidance on tax accounting issues (PwC) More

  • US: Regulatory perspectives on accounting for income taxes (KPMG) More

  • Vietnam: Capital transfer tax for foreign corporate sellers under new decree (Alvarez & Marsal) More

 

 

Monday, January 5

  • Global: International tax news (December 2025) (PwC) More

  • Global: Opinion statement on the OECD consultation on the global mobility of individuals (CFE Tax Advisers Europe) More

  • Global: Tax treaty round-up: Changes effective as from 1 January 2026 (Deloitte) More

  • Global: Updated CARF and CRS FAQs released (Deloitte) More

  • Argentina: Changes to transfer pricing regimes; amendments to system for issuing receipts using “fiscal controllers” (KPMG) More

  • Bahrain: Updated VAT deregistration manual and domestic minimum top-up tax (DMTT) FAQs (KPMG) More

  • Bermuda: Tax Credits Act 2025 and Corporate Income Tax Amendment (No. 2) Act 2025 enacted (Deloitte) More

  • Brazil and Netherlands: Dutch Advocate General confirms IoNE qualifies exclusively as dividend under NL-Brazil tax treaty (Loyens & Loeff) More

  • Bulgaria: Lukoil case – transfer pricing – price for intragroup purchase of goods and interest rate on intragroup loan – TNMM and CUP methods (Supreme Administrative Court decision) (in Bulgarian) (TPcases) More

  • China: Annual APA report (KPMG) More

  • China and US: USTR announces tariffs following Section 301 investigation into China's semiconductor industry practices: tariffs will increase in 18 months—on June 23, 2027 (KPMG) More

  • Colombia: Emergency tax measures to fund 2026 national budget adopted (KPMG) More

  • Egypt: Threshold for transfer pricing documentation doubled (Deloitte) More

  • France: Société Générale case – transfer pricing – incurring of costs for benefit of foreign subsidiaries (France Supreme Administrative Court decision) (in French) (TPcases) More

  • France: Special law to guarantee continuity of nation adopted (Deloitte) More

  • Hong Kong: Consultation launched on implementation of CARF and amended CRS (Deloitte) More

  • Hong Kong: Public consultation on implementation of cryptoasset reporting framework (CARF) and CRS 2.0 (KPMG) More

  • Hungary: Advertisement tax regime to resume July 1, 2026 (KPMG) More

  • India: Income from delivery order charges not subject to tax in India under UK treaty (tribunal decision); other recent direct and indirect tax developments in India (KPMG) More

  • Japan: Corporate and tax quarterly update: December 2025 issue (Baker McKenzie) More

  • Mexico: Miscellaneous tax resolution for FY2026 (KPMG) More

  • Middle East: Pillar Two: Middle East round-up (PwC podcast) More

  • Netherlands: 2026 Tax Plan approved by upper house of Parliament, including Pillar Two changes and implementation of DAC9 (KPMG) More

  • Netherlands: Interest expense may be non-deductible when acquisitions financed with shareholder loans (Supreme Court decision) (KPMG) More

  • Poland: Remitter of dividends obligated to verify authenticity of ownership structure (Supreme Administrative Court decision) (KPMG) More

  • Sri Lanka: Amendments to social security contribution law: new exemption for persons providing financial services subject to 20.5% VAT (KPMG) More

  • Sweden: Taxation under Sweden-UK treaty of dividends covered by UK foreign income and gains rules (Tax Court advance ruling) (KPMG) More

  • Switzerland: Implications of Zug case and Switzerland’s commitment to calendar year-based transfer pricing enforcement (KPMG) More

  • Tanzania: Aggreko case – transfer pricing – allocation of head office expenses (Court of Appeal decision) (TPcases) More

  • Thailand: Issue of secondary legislation on GloBE rules (Tax authorities) More

  • UAE: Guidance on advance pricing agreements (Tax authorities) More

  • UAE: Guidance on tax compliance obligations for qualifying investment funds and their investors (KPMG) More

  • UK: VAT costs deductible when professional fees directly linked to taxable sale (Supreme Court decision) (KPMG) More

  • US: Final and proposed section 892 regulations: analysis and observations (KPMG) More

  • US: IRS issues FAQs regarding section 163(j) limitation following amendments by OBBBA (KPMG) More

  • US: Notice 2026-01 provides safe harbour for section 45Q carbon capture credit for 2025 (Deloitte) More

  • US: State tax matters (Deloitte) More

  • US: US postpones increase in tariffs on imports of certain wood products (KPMG) More

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