AI-Juiced Cross-Border Services Business Boom Raises Tax Issues

A wave of artificial intelligence tools is opening the door to new business opportunities and supercharging questions about how to tax service-based industries with clients that span the globe.

India Supreme Court Boosts Foreign Companies’ Tax Arguments

The Supreme Court of India is providing support for foreign companies fighting tax department claims that subsidiaries in the country constitute permanent establishments, with the tax liabilities they bring.

UK Backs Off Transfer Pricing Rules for Medium-Sized Companies

The UK government will drop its plan to bring medium-sized businesses under the country’s transfer pricing rules.

Treasury, IRS Withdraw Tax Return Preparer Oversight Proposal

The Treasury Department and IRS withdrew proposed rules regarding which tax return preparers are eligible to obtain a preparer tax identification number.

OECD Peers Advised 26 Countries to Improve Tax Ruling Exchanges

The OECD asked 26 countries to improve their facilitation of tax rulings that help tax authorities in risk assessments and counter base erosion and profit shifting concerns, according to a new report.

Latest Stories

Global Services Boom Boosts Tax Issues: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re taking a look at what new AI tools proliferating around the world could mean for cross-border business, and the sticky tax and transfer pricing issues that could bring.

Tax Developments

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Israel MOF Posts Second Protocol to 1962 DTA With U.K. in English, Hebrew

The Israeli Ministry of Finance Dec. 17 posted online, in English and Hebrew, the second protocol to the 1962 DTA with the U.K., signed Sept. 17, 2019. [Israel, Ministry of ...

Hong Kong Signs DTA, Protocol With Norway

The Hong Kong Inland Revenue Department Dec. 16 announced the same date signing of a DTA and protocol with Norway. [Hong Kong, Inland Revenue Department, 12/16/25]

Austria MOF Clarifies PE Status of Nonresident Subcontractors Under OECD Model Tax Convention

The Austrian Federal Ministry of Finance Dec. 16 posted BMF Letter No. 2025-1.019.512, clarifying the permanent establishment (PE) status of nonresident subcontractors under the OECD Model Tax Convention. The clarification ...

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