THE NEW PILLAR TWO FRAMEWORK: UNBOXING THE SIDE-BY-SIDE PACKAGE
January 6, 2026
The OECD’s new Pillar Two Side-by-Side package introduces key safe harbours and simplifications, with implementation beginning in 2026.
OBBBA International Tax Guidance: What’s New, What’s Looming
January 6, 2026
New Treasury and IRS guidance under the OBBBA signals meaningful changes for international tax planning. Key implications are emerging now, with more to come in 2026.
Singapore Transfer Pricing Guidelines (Eighth Edition)
December 30, 2025
IRAS TPG8 Transfer Pricing updates: domestic loan relief, cross-border loan rules, SSA pilot, protective MAP, strict pass-through costs, documentation.
Supreme Court clarifies the Scope of Deduction of Head Office Expenditure for Non-Residents as enshrined under section 44C of the Income Tax Act, 1961
December 26, 2025
The Supreme Court of India (SC) has pronounced a landmark judgment (the Ruling) in the case of American Express Limited and Oman International Bank (the Taxpayers), which will have a significant impact on non-residents operating in India through a branch structure.
