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Europe
- EU: EU withdraws overarching transfer pricing directive – click here;
- EU: European Commission recognizes OECD Pillar Two side-by-side safe harbors – click here and here;
- UK: UK transfer pricing - Finance Bill changes – click here;
- UK: UK joins the ‘Median Club’ with its transfer pricing adjustments – click here;
- UK: His Majesty's Revenue and Customs (HMRC) publishes draft guidance on transfer pricing, permanent establishments (PEs), and diverted profits tax (DPT) reforms – click here;
- Ireland: Extension of Pillar Two registration deadline to February 28, 2026 (previously December 31, 2025) – click here;
- Isle of Man: Isle of Man publishes Mutual Agreement Procedure (MAP) guidance – click here;
- Iceland: Revenue and Customs announces 2025 Country-by-Country (CbC) report submission deadline – click here and here;
- Belgium: Transfer pricing studies not required to be submitted with local file form – click here and here;
- Netherlands: 2026 Tax Plan approved by upper house of Parliament, including Pillar Two changes and implementation of DAC9 – click here;
- Germany: Updated guidance issued on use of OECD model commentary in tax treaty interpretation – click here;
- Denmark: Expanded scope of Country-by-Country (CbC) reporting under DAC9; amendments to Pillar Two rules – click here;
- Montenegro: Montenegro ratifies Base Erosion and Profit Shifting (BEPS) Multilateral Instrument, covering 40 tax treaties – click here;
- Hungary: Hungary updates transfer pricing documentation framework – click here;
- Poland: Ministry of Finance (MoF) updates 2024 transfer pricing guide on foreign currency conversion – click here;
Global
- OECD: Tax challenges arising from the digitalisation of the economy – Global anti-base erosion model rules (Pillar Two), side-by-side package – click here for the publication and here for an overview;
- OECD: KPMG report: 2025 update to OECD Model Tax Convention – click here;
- Australia: Australia updates transfer pricing guidance on inbound distribution arrangements – click here;
- Singapore: The Inland Revenue Authority of Singapore (IRAS) updates transfer pricing guidance, raises indicative margin for related party loans – click here for the January 2026 guidance and here for the November 2025 guidance;
- Egypt: Threshold for transfer pricing documentation doubled from EGP 15 million (approx. EUR 273,000) to EGP 30 million (approx. EUR 547,000) – click here;
- Cameroon: Guidance on mutual agreement procedures (MAPs) – click here;
- UAE: The UAE Federal Tax Authority updates corporate advance pricing agreements guidance – click here;
- Japan: Outline of 2026 tax reform proposals, including amendments to Pillar Two rules – click here;
- China: Annual Advance Pricing Agreement (APA) report – click here;
- Argentina: Changes to transfer pricing regimes; amendments to system for issuing receipts using “fiscal controllers” – click here;
Romania
- Romania’s new transfer pricing law - major risks multinationals must prepare for – click here for the article and here to listen to the podcast;
- How the amendments to the Tax Procedure Code apply to payment deferrals, effective from January 1, 2026 – click here and here;
- Emergency Ordinance No. 71/2025 amending and supplementing Law No. 207/2015 on the Tax Procedure Code – click here;
- Emergency Ordinance No. 89/23.12.2025 amending and supplementing Law No. 227/2015 on the Fiscal Code – click here for the Emergency Ordinance and click here and here for the articles;
- Tax anomaly arising from Tax Package 2 and Emergency Ordinance No. 89/23.12.2025 - Some companies will pay both income tax and oil and gas tax (ICAS), as well as the tax on affiliates – click here;
- Tax changes for 2026. The main legislative changes you need to be aware of this year – click here and here;
- Minister of Finance - 2026 must be the year in which Romania officially joins the OECD – click here;
TP Cases
- Romania: Only 2 years and 9 months to complete an amicable procedure (MAP) for a Romanian taxpayer – a subsidiary of an Italian group – click here;
- Belgium: Key Belgian Court decision on intra-group financing and transfer pricing – click here;
- Switzerland: KPMG report: Implications of Zug case and Switzerland’s commitment to calendar year-based transfer pricing enforcement – click here;
- USA: Meta contests $16 Billion in deficiencies in U.S. Tax Court – click here and here;
