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DAC6
- Access the DAC6 Comparison Tool App that allows the user to make instant comparisons among DAC6 provisions in different countries. Plus, it offers direct links to each local legislation and guidelines and shows you how to perform the MBT test – click https://comparison.dac6guide.eu/#/
- For the latest developments and news concerning DAC6 – click here
Romania
- NAFA strategy for 2021 – 2024: reducing the fiscal gap to VAT by "up to 10%" and employing 2,000 people. Returning to the 2019 level on compliance / Controls will target many individuals (RO) – click here
- An ambiguity, two finance ministers, no solution. The issue of gift vouchers is now at Nazare / NAFA is looking especially at eMag vouchers (RO) – click here
- The provision of measures - a questionable practice in the context of anti-fraud controls? (RO) – click here
- Mihaela Mitroi, EY: "In the tax inspection, quality must prevail, not quantity" (RO) – click here
- NNDKP wins case related to the annulment of documents issued by the tax authorities with respect to transfer pricing matters (ENG/RO) – click here and here
- Reff & Associations | Deloitte Legal obtains a final victory before the HCCJ which confirms the deductibility of expenses with management and support services provided within a group of companies (RO) – click here
Europe
- Netherlands: Proposals on TP adjustments and taxation of reverse hybrid entities – click here
- A review of advance tax agreements in Italy – click here
- The implementation in Italy of EU Council Directive 2017/1852 on tax dispute resolution – click here
- Moving forward to find solutions – ITR's Italy Special Focus launched – click here
- This week in tax: DAC7, DAC8 and Cairn’s tax dispute – click here
- EU Finance Ministers exchange views on digital taxation while the Commission announces it may introduce a digital levy separate from OECD’s Pillar One – click here
- EU to implement digital levy regardless of OECD-led effort – click here
- CJEU confirms Polish and Hungarian progressive turnover taxes do not violate EU law – click here
- Luxembourg: Guidance on mutual agreement procedures – click here
- Ireland consults on adoption of authorized OECD approach for attributing profits to branches – click here
Global
- Incoming OECD secretary-general to face higher tax policy pressures – click here
- UN tax committee to issue proposed model treaty language on taxing rights for automated digital services – click here
- Country-by-country multinational tax reporting ‘will happen’, says McGuinness – click here
- Canadian mining company seeks NAFTA arbitration in Mexico transfer pricing dispute – click here
- Canada: CRA report on MAP program and statistics for 2019 – click here
- Amending Australia's Offshore Banking Unit Regime – click here
- NGOs dispute UN proposal deeming software payments as royalties, arguing it would perpetuate a confused notion of “copyright,” retroactively diminishing state taxing rights: BEPS Monitoring Group – click here
- Transfer pricing for Indian software distribution affiliates – click here
- Dominican Republic issues draft amendments to transfer pricing regulations – click here
- Mongolia issues first transfer pricing assessment – click here
- Bahrain introduces Country-by-Country Reporting – click here
