Hey, here we are again at Monday. Guess we should get to it.
In this news brief
A Less Thrilling Transfer Pricing Story
For those of you interested in both UK tax law and transfer pricing cases, here’s a case study from the Wolters Kluwer International Tax Blog. What a thrilling way to start a Monday!
The United Kingdom First-tier tax Tribunal has declined to order the disclosure of a US parent company’s group consolidated financial statements and US entity level financial statements in a case concerning a transfer pricing enquiry by the HMRC. the enquiry by the UK tax authority was into transactions between the US parent company and its UK resident subsidiary. The case usefully casts light on when information is “reasonably required “ for the administration of UK tax law and when it might be “foreseeably relevant” for exchange of information under article 26(1) of the OECD and UN Model treaties.
In Lifeplus Europe Ltd v HMRC [2026] UKFTT 797 (TC), the Tribunal considered whether parent company financial statements were “reasonably required” by HMRC to check the UK resident subsidiary’s tax position or whether it was a “fishing expedition”. Although the domestic term “reasonably required” in Finance Act 2008, Schedule 36 paragraph 1 is not identical to the “foreseeably relevant” treaty term, there are close parallels.
Not nearly as sexy as the Coca-Cola transfer pricing case making its way to your boomer dad’s eyeballs via his iPad news app as we speak.
The Ghost of Tax Preparer Fraud Past
In Supreme Court news, the nation’s highest court will not be hearing a case about time limits on tax preparer fraud, reports Bloomberg Tax:
The US Supreme Court declined Monday to hear a case challenging the IRS’ unlimited time period to impose penalties on taxpayers when their tax preparers commit fraud.
The court’s decision to decline Stephanie Murrin’s case allows a Third Circuit ruling against her to stand. Murrin’s tax preparer filed fraudulent returns on her behalf in the 1990s but wasn’t audited until 2019. She argued the IRS shouldn’t have an unlimited amount of time to investigate tax fraud when the fraud is committed by a third party.
17-page PDF on the case if you want to check it out here.
Who Doesn’t Want Nasty Calls From Angry KPMG Partners
We’re working on an ICYMI post outlining everything that’s been happening at KPMG Australia in the last few months, in the meantime all you need to know is that it’s a shitshow that keeps getting worse for the firm. How’s this for a headline: KPMG’s corporate virtue signalling hid poor business culture.
Writes Aaron Patrick for The Nightly:
The abusive phone call came through when I was about to arrive at home after a day’s work. A top executive at the giant financial services firm KPMG had rung to express his anger over an article that revealed KPMG asked job applicants sensitive questions about their sexuality.
“Please select the identity below that best describes your gender,” KPMG had asked in an online job application form. “Do you have a trans or other gender diverse experience or history (including but not limited to Brotherboy/Sistergirl, Third Gender)? Do you have an Intersex variation?”
After a minute or two of verbal aggression that conveyed the message “how dare you write this about us”, the executive ended the call after briefly hearing out my mild-mannered defence of truthful reporting.
I’m happy to say I’ve never gotten any angry phone calls from KPMG, they’re perfectly cordial with us and will even waste time answering tedious questions like “does Lakehouse have hair dryers?” To be fair, the situation at KPMG Australia is a bit more serious than hair drying.
Anyway, getting back to the point of the The Nightly article:
Although the conversation took place four years ago, KPMG’s approach to scrutiny is relevant today. The firm stands accused of a gross breach of trust, including misusing clients’ information, trying to fire a whistleblower who revealed the abuse and pretending it investigated the initial complaint when it didn’t.
While all the facts are not clear, many people might wonder: could the companies that try hardest to prove themselves virtuous be the ones with the most to hide?
Meanwhile, Financial Review is still going hard covering the unraveling. Exhibit A: Inside the law firm probes that let KPMG cloak itself in secrecy
Big 4 Firms in India Are Doing Great…Maybe
The Economic Times says Big 4 firms in India — not to be confused with Big 4 firms’ global delivery centers operating out of India — are thriving.
The Indian units of the Big Four firms closed fiscal year 2026 as some of the fastest-growing operations within their global networks, at a time when growth remained sluggish in mature markets, the lucrative Middle East market slowed and some regions continued to see layoffs.
In FY26, PwC reported around Rs 14,000 crore in gross revenue with 21% growth, Deloitte clocked Rs 14,500 crore with 22% growth. KPMG’s revenues crossed Rs 10,000 crore, including royalties, a one-off asset sale and revenue from KDN, its global delivery centre. And EY, whose fiscal year ends on June 30, has surpassed Rs 16,000 crore, according to two senior partners who spoke on condition of anonymity.
Google says Rs 16,000 crore is $1,693,051 USD. Is that right? $1.7 million?
But there’s a but:
Comparing the firms, however, is not straightforward.
The firms, which operate as private partnerships, are locked in a race to appear bigger and have increasingly adopted different revenue reporting styles. Some include out-of-pocket expenses billed to clients, GST, royalties received to global headquarters, subcontracted work, India-centric work executed through global delivery centres and even asset sales, creating a 10%-25% variation in revenue figures.
Where are we at with India making their own megafirms to compete with Big 4? Haven’t heard anything about that since September.
PwC’s Bleak Forecast For Gaming
GamesBeat wrote up the gaming side of PwC’s Global Entertainment & Media Outlook 2026-2030 report and spoke to CJ Bangah, PwC partner and analyst on games and esports.
The U.S. games and esports industry is expected to hit a cyclical slowdown driven by weak economic trends in 2027 — despite the launch of Grand Theft Auto VI on November 19, 2027, according to a new report on games and esports by consulting and accounting giant PwC.
What an unfortunate typo. It’s November 19, 2026.
The reasons for the weakness in 2027 is that the Xbox and PlayStation consoles are expected to be in the last year before a relaunch in 2028, based on the best industry knowledge. That means that 2027 is a transition year, where sales are typically in a cylical downturn. On top of that, sales for GTA VI could lift 2026 results, but they may not be quite enough to lift 2027.
And there are other factors such as economic and political uncertainty (related to the war with Iran and more), tariffs and the memory chip price increases related to huge demand for AI. The latter has resulted in artificially high prices for gaming hardware, keeping systems out of the reach of many in the broader gaming market.
You guys hear about that $2,960 PS5 SSD? Gaming is going to be bleak for a while.
Dodd-Frank’s Longstanding Ambiguities
Fans of open public comment will be exhilarated by this one:
A joint request for comment from two top U.S. financial regulators aims to address “longstanding ambiguities” of the Dodd-Frank Act.
On Thursday, the Securities and Exchange Commission and the Commodity Futures Trading Commission announced that they’re seeking public comment on “potential opportunities to further update, clarify, and harmonize certain derivatives product definitions and interpretive issues,” including the use of perpetual futures contracts and the definition of security-based swaps.
In a news release, SEC Chairman Paul Atkins said that “clarification is long overdue” on the Dodd-Frank Act’s Title VII, a component of the 2010 law aimed at providing a regulatory framework for swap markets.
Good that we’re getting around to this finally.
And that’s it for this news brief, I know you have work to get to. Email or text if you have a tip or story for us and at least try to enjoy your week OK?
