Worldwide: Transfer Pricing

Discover how artificial intelligence is transforming tax law and intellectual property, while examining critical issues of tax rates and wealth inequality in modern America. Professor Jeremy Bearer-Friend from George Washington University Law School shares expert insights on these evolving challenges in the tax landscape.

When US multinationals establish operations in Europe, determining how much profit should be allocated to a permanent establishment becomes critical. The Authorised OECD Approach requires a functional...

The U.S. Treasury Department and IRS have issued proposed regulations addressing two significant changes to the Internal Revenue Code made under the One Big Beautiful Bill Act: the allocation of foreign income taxes following the repeal of the one-month deferral election for controlled foreign corporations, and the new partial foreign tax credit disallowance on certain previously taxed earnings and profits distributions. These regulations introduce four new elections that provide taxpayers with greater flex

African governments are rapidly modernising their approach to tax and customs in the resources sector. Fiscal tools, tighter compliance frameworks and procedural reforms are reshaping investment and operational conditions across the continent.

In May, the I.R.S. announced a settlement offer for partnerships involved in disputes concerning "syndicated conservation easements." The key features of the offer include a 10% penalty for gross valuation misstatement, instead of a 40% penalty, and no upfront payment required.

At a Washington tax conference on May 20, Treasury Assistant Secretary for Tax Policy Kenneth Kies reportedly signaled that anti-stacking regulations targeting Code §1202 qualified small business stock (“Q.S.B.S.”) are likely forthcoming.

On January 9, 2026, the final text of the Supplementary Law ("LC") No. 225/2026 was published in the Official Gazette of the Federal Government, which launches the Taxpayers´ Defense Code (the "Code").

The IRS recently issued a Chief Counsel Advice Memorandum (AM 2025-002) that provides helpful guidance regarding the application of the branch profits tax in connection with reverse foreign hybrid entities and U.S. income tax treaties with foreign countries.

On January 5, 2026, the OECD Inclusive Framework (IF) on Base Erosion and Profit Shifting (BEPS) released the highly anticipated Side-by-Side (SbS) package.