Week in Insights: NIL Era Brings Threat of Tax Exemption Abuses
This week, experts examined the IRS’s fast track settlement program, Canada’s proposed transfer pricing reforms, and more.
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.
The UK government will drop its plan to bring medium-sized businesses under the country’s transfer pricing rules.
The Treasury Department and IRS withdrew proposed rules regarding which tax return preparers are eligible to obtain a preparer tax identification number.
Many countries expressed concern Wednesday about a proposal that the United Nations set up and run a database to help developing nations have access to transfer pricing information under a new global tax treaty.

Singapore is launching a pilot program for taxpayers to use the OECD’s simplified and streamlined approach to transfer pricing.

This week, experts examined the IRS’s fast track settlement program, Canada’s proposed transfer pricing reforms, and more.
Hello and welcome to the Transfer Pricing Report. I’m Kathy Larsen, standing in while Caleb Harshberger is away. We miss him a lot, but we’re all over activity in the UK, where HMRC said it won’t pull medium-sized companies into its transfer pricing net after all, and in India, where the Supreme Court took a stand on permanent establishment.
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.
The UK government will drop its plan to bring medium-sized businesses under the country’s transfer pricing rules.
Switzerland’s government approved Wednesday a regulatory amendment establishing a centralized filing procedure for global minimum tax information returns and their sharing with cantonal and international authorities.
The Treasury Department and IRS withdrew proposed rules regarding which tax return preparers are eligible to obtain a preparer tax identification number.
The CJEU clarifies the VAT treatment for manufacturers’ tooling purchases from subcontractors.
A group of Republican lawmakers on Tuesday called for the Trump administration to reopen its trade investigation into a French tax on digital services.
This week, experts analyzed IRS shutdown shock waves, the tax case of Publix heiress Julia “Julie” Jenkins Fancelli, and more.
More than 300 preferential tax regimes that encourage companies to shift their profits and avoid paying tax have been amended or abolished, according to an OECD report released Saturday.
The Slovak Financial Administration Nov. 24 posted Guide No. 3/MZ/2025/I, on determining the content of transfer pricing documentation under Ministry of Finance Guideline No. MF/012879/2025-724 and the Income Tax Act. ...
The Chilean Internal Revenue Service Nov. 12 opened a consultation on a draft circular on applying the most favored nation (MFN) clause in various DTAs, on maximum withholding rates for ...
The Croatian Parliament (Sabor) Nov. 21 passed Bill No. PZ 220, to ratify the second protocol to the 1999 DTA with Switzerland, signed July 18. [Croatia, Parliament, 11/21/25]
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