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UK Court of Appeal compares risks, rules on interest-deductibility qua intra-group loans vis-a-vis Blackrock's acquisition of Barclays

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US IRS releases 25th APA Report; Highlights execution of 156 APAs, almost half of pending BAPAs requests involve Japan/India

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Kenya Tax Tribunal dismisses Beta Healthcare's appeal on failing to discharge burden of proof on disputed information

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Australian Federal Court dismisses SingTel’s appeal on cross-border related party financing dispute

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Holds APA not applicable to future years unless specified; Quashes review claim

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US Tax Court rules out Brazilian legal restriction in determining ALP for intangibles in Coca-Cola’s case

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OECD releases 2022 MAP Statistics, Awards and 2023 Consolidated Information on MAP

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OECD invites public comments on additional toolkit for applying TP framework by developing countries to a specific mineral - lithium

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OECD releases sixth annual peer review of BEPS Action 13 covering 136 member countries

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OECD & IGF release public comments on toolkits to address BEPS risks in pricing minerals

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Inclusive Framework records almost 50,000 information exchange upto 2021, significant progress on Action 5

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OECD recognises jurisdictions for speedy dispute resolution; India MAP stats ‘middling’

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Major jurisdictions agree to share information on digital economy, offshore financial assets

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US Tax Court issues supplemental opinion, holds CUT not best method to determine ALP in Medtronic’s case

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US Court of Appeal points out IRS’s limited discretion in cancelling APAs; Provides penalty relief to Eaton Corporation

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UK Court allows HMRC’s appeal against First-tier Tribunal on TP issue in Blackrock's case

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ATO releases Consultation paper on thin capitalisation, royalty and intangibles deduction rules; Invites comments

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Netherlands introduces new TP decree, aligns it with OECD; New section on Cash Pooling introduced

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OECD releases fourth batch of TP country profiles for four new countries; Increases participation score to 73

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OECD invites comments on public consultation over tax certainty on 'Framework' and 'Issues Related' to Amount A