Isle of Man publishes MAP guidance
December 23, 2025The Income Tax Division of Isle of Man has published detailed guidance on mutual agreement procedure (MAP) framework under tax treaties.
Indian Supreme Court rules on head office expense deduction
December 23, 2025The Indian Supreme Court, on December 15, returned a finding on the interpretation of section 44C of the Income Tax Act, on whether it merely covers “common expenditure” incurred by the head office attributable to a taxpayer’s business in India, or would also include “exclusive expenditure” incurred by the head office for the Indian branches.
Indian tax authority wins PE tax case against Hyatt International
July 24, 2025In a big win for the Indian tax authority, the Supreme Court today said that the UAE-based Hyatt International Southwest Asia Limited (Hyatt International) has a fixed place permanent establishment (PE) in India under the India-UAE tax treaty.
G7 chickens out on global minimum tax, exempts US
July 3, 2025The Group of Seven member countries have agreed to exempt the United States from the 15 percent global minimum corporate tax rate.
Indian 2025 budget includes international tax measures
February 1, 2025Indian Finance Ministry has released the country’s 2025 Budget, which includes key international tax changes.
Trump threatens global minimum tax deal
January 22, 2025US President Donald Trump has announced withdrawal of the United States from the global minimum tax deal supported by over 100 countries.
Japan’s global minimum tax law: long road ahead
July 18, 2023Takato Masuda of Nishimura & Asahi, Tokyo, provides an overview of what Japan has done so far, and what remains to be done on implementing the global minimum tax, especially in light of the guidance issued by the OECD on July 17, 2023.
Transfer Pricing Reform in Brazil and ‘Options Realistically Available’: New Tax Disputes Ahead?
July 4, 2023Law No. 14596/2023 introduced new transfer pricing rules in the Brazilian tax system, in line with the arm’s length standard.
By Ramon Tomazela, Partner, Mariz de Oliveira & Siqueira Campos Advogados
So you dislike the OECD global minimum corporate tax? Tough. The UK now has to implement it, or we’ll lose out.
June 27, 2023So you dislike the OECD global minimum corporate tax? Tough. The UK now has to implement it, or we’ll lose out. By: Dan Neidle, Tax Policy Associates
Panama Supreme Court on tax arbitration
November 22, 2022By Rafael Rivera Castillo (Managing Partner, BDO, Panama)
Pakistan court rules on taxability of EPC contracts
July 14, 2022Muzammal Rasheed is Chief Executive Officer of Enfoque Consulting (Private) Limited, Pakistan, a member firm of WTS Global.
Implemented modifications to the German Transfer Pricing Legislation
March 2, 2022By Dr. Björn Heidecke, (Director, Transfer Pricing, Deloitte, Germany) & Neeraj-Kumar Popat (Senior Manager, Transfer Pricing Deloitte, Germany)
What is Transfer Pricing, Definition, Overview under Indian law
August 10, 2021By CA. Akshay Kenkre (Founder and Practice Lead, TransPrice Tax Advisors LLP, India)
Delhi Court rejects virtual service PE under India, Singapore tax treaty
December 23, 2025India’s Delhi High Court has ruled that services provided remotely by a foreign enterprise to Indian clients do not create a taxable permanent establishment (PE) in India under the India-Singapore tax treaty.
San Marino ratifies Pillar Two Subject to Tax Rule
December 23, 2025San Marino, on December 11, 2025, became the first jurisdiction to deposit its instrument of ratification for the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (the STTR Convention), the OECD said.
OECD publishes peer review reports on harmful tax practices
December 23, 2025New peer review results published by the OECD show strong compliance with BEPS Action 5 minimum standard on the exchange of information on tax rulings.
Germany to not initiate or renew tax APAs with China
July 28, 2025Germany will not enter into any fresh advance pricing agreement (APA) with China, the German Federal Tax Office has said.
Qatar, Uruguay sign tax treaty
December 23, 2025Qatar and Uruguay have signed a tax treaty on December 7.
Tax treaty between Switzerland, Jordan enters into force
December 23, 2025The tax treaty between Switzerland and Jordan has entered into force and will generally apply from January 1, 2026.
Hong Kong, Norway sign tax treaty
December 23, 2025Hong Kong and Norway signed a tax treaty on December 16 in Beijing.
Japan, Kyrgyz Republic sign tax treaty
December 23, 2025On December 19, 2025, officials from Japan and the Kyrgyz Republic signed a tax treaty in Tokyo.
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