Europe
- Poland clarifies its unique definition of “controlled transaction” for transfer pricing purposes – click here
- Changes ahead for UK transfer pricing documentation – click here
- Ireland consulting on tax treaty policy – click here
- Ireland positions itself as counterpoint to US in debate over global minimum tax – click here
- Tax governance and the increased focus on TP in Luxembourg – click here
- Malta: Update on expectations for transfer pricing rules – click here
- Italian Supreme Court rules on uneconomical inter-company transactions – click here
- ECJ to rule on whether DAC 6 tax reporting obligation infringes rights – click here
Romania
- Today’s optimistic news – this „Path” is from Romania (RO) – click here
- Who (still) saves us from double taxation? (RO) – click here
- NAFA hopes companies will register for the SAF-T test, estimated to take place during the summer. Five questions from the business community and NAFA’s answers (RO) – click here
- NAFA has to recover from taxpayers (i.e. companies and individuals) debts of RON 2.26 billion resulting from the fiscal deferral payment facility from last year and for which the simplified rescheduling mechanism has not been accessed (RO) – click here
Global
- OECD releases new MAP peer review reports – click here
- OECD releases peer review reports on tax treaty shopping and abuse – click here
- OECD releases fourth batch of Stage 2 peer review reports on dispute resolution – click here
- Fabrizia Lapecorella to chair OECD’s Committee on Fiscal Affairs from 2022 – click here
- Ireland, Mexico among countries struggling to timely resolve MAP tax and transfer pricing cases – click here
- Switzerland – Double Taxation Treaty with Brazil Entering into Force – click here
- This week in tax: General Electric wins battle with HMRC – click here
- Netflix Korea reports its 2020 financials: transfer pricing implications – click here
- UN committee considers updates to model tax treaty, developing nation tax guidance – click here
- Tax Administration: Digital Resilience in the COVID-19 Environment – click here
- UN Committee of Experts approves new digital tax article for model treaty – click here
- Digital platforms should assist tax compliance efforts, OECD says – click here
- Global agreement on new nexus rules and minimum tax likely by October, Saint-Amans says – click here
- Tax, people and technology: Think big, start small – click here
- Canada’s 2021 budget includes proposals on digital taxes, profit shifting, interest deductibility – click here
- Brazil’s isolated approach to the arm’s-length principle – click here
- Maldives publishes advance pricing arrangement regulations – click here
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
- Spain approved DAC6 forms – click here