In late 2025, the UK government introduced significant changes to the transfer pricing framework through the Finance (No. 2) Bill 2025–26. These reforms, which are expected to generally apply to accounting periods beginning...more
2/16/2026
/ Corporate Taxes ,
Cross-Border Transactions ,
Diverted Profits Tax ,
HMRC ,
International Tax Issues ,
New Legislation ,
OECD ,
Proposed Legislation ,
Reporting Requirements ,
Tax Avoidance ,
Tax Legislation ,
Tax Reform ,
Taxation ,
Transfer Pricing ,
UK
Overview -
As part of the 2025 Autumn Budget announcements, the UK Government confirmed that it will introduce legislation requiring certain multinational enterprises to file an annual International Controlled Transactions...more
12/12/2025
/ Cross-Border Transactions ,
HMRC ,
International Tax Issues ,
Multinationals ,
New Legislation ,
Proposed Legislation ,
Regulatory Requirements ,
Reporting Requirements ,
Taxation ,
Transfer Pricing ,
UK
The OECD’s 2025 update to the Model Tax Convention marks a significant shift in how tax treaties address cross border remote work, natural resource activities and a number of important technical issues around transfer...more
12/12/2025
/ BEPS ,
Cross-Border Transactions ,
Dispute Resolution ,
Exchange of Information ,
International Tax Issues ,
Natural Resources ,
OECD ,
Oil & Gas ,
Remote Working ,
Tax Policy ,
Tax Treaty ,
Taxation ,
Thin Capitalization ,
Transfer Pricing
Last year, in our article “OECD’s 2023 MAP and APA Statistics: Key Insights for Multinational Enterprises”, we analysed the inaugural global statistics on Advance Pricing Arrangements (APAs) alongside the longstanding mutual...more
11/11/2025
/ Advance Pricing Agreements ,
Corporate Taxes ,
Cross-Border Transactions ,
Dispute Resolution ,
Double Taxation ,
International Tax Issues ,
Jurisdiction ,
Multinationals ,
Mutual Agreement Procedure ,
OECD ,
Risk Management ,
Tax Planning ,
Tax Treaty ,
Taxation ,
Transfer Pricing