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.

Nations Warn UN-Run Transfer Pricing Database Would Be Pricey

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 to Let Taxpayers Try Simplified Transfer Pricing Rules

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

Latest Stories

UK SME Exemption, India PE Ruling : Transfer Pricing Report

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.

Tax Developments

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Slovakia Tax Agency Issues Guide on Transfer Pricing Documentation

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. ...

Chile Tax Agency Seeks Comments on Draft Circular on Applying MFN Clause in Various DTAs

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 ...

Croatia Parliament Passes Bill to Ratify Second Protocol to 1999 DTA With Switzerland

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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