On the 20th of January 2022, the OECD published new Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Some of the significant changes pertain to the guidance on the application of the transactional profit method and hard-to-value intangibles (HTVI) agreed upon in 2018, as well as revisions to the guidance for financial transactions from 2020.
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The Spanish Tax Agency (AEAT) is redefining how tax risk is assessed. The 2026 Tax Control Plan confirms a clear shift. Tax audits are becoming
In January 2026, the Czech Regional Court issued a significant ruling in Czech Republic v. Hitachi Astemo Czech s.r.o. (Case No. 15 Af 10/2023–128), addressing
In January 2026, Kenya’s Tax Appeals Tribunal delivered an important decision in the dispute between Del Monte Kenya Limited and the Kenya Revenue Authority (KRA).
