brought to you by TPS
Europe
- Denmark finally implements ATAD amendments to CFC regime – click here
- Germany adopts ATAD rules on exit taxation, CFCs, hybrids – click here
- Iceland: Penalty provisions introduced for transfer pricing documentation noncompliance – click here
- Netherlands: Interest deduction denied in acquisition structure (Dutch Supreme Court) – click here
- Nike’s transfer pricing state aid dispute: the underlying issues – click here
- Ireland seeks input on OECD tax proposals’ impact on Irish tax policy – click here
- At least three reasons why Ireland is right to resist 15% global corporate tax push – click here
Global
- Multilateral dispute resolution initiatives: Time for a global reset? – click here
- TP controversy: The dynamic landscape of intangibles arrangements – click here
- A closer look at debt transactions in practice – click here
- The cause-and-effect relationship between COVID-19 and tax controversies: Risk management avenues for taxpayers – click here
- Country-by-country reporting and COVID-19: CbC data is becoming a big deal in TP controversy – click here
- MAP developments in the desk-bound age – click here
- TP developments are rapidly creating the new normal in global TP controversy – click here
- Settling into the new normal world of TP controversy – click here
- H1 2021: Top 100 most-read ITR Expert Analysis articles – click here
- Brazilian tax reform’s second phase includes corporate, investment proposals – click here
- Mexico’s outsourcing schemes’ demise and its tax and transfer pricing effects – click here
- Costa Rica: Change to taxpayer status for failures to file returns – click here
- United Arab Emirates publishes MAP guidance for resolving tax and transfer pricing disputes – click here
- Oman suspends local filing transfer pricing reporting requirement – click here
- Philippines, Brunei sign double taxation agreement seen to generate investments, create jobs – click here
- Bangladesh: Income tax, VAT measures in Finance Act 2021 – click here
- Gibraltar: Increased tax rate for companies, temporary allowances – click here
- Australia designing tax policy for patent box – click here
- Kenya’s Finance Act 2021 amends tax policy approach to global market – click here
- Sri Lanka: Transfer pricing rules, documentation requirements – click here
- US IRS advises on transfer pricing adjustments for Altera-related ‘reverse claw-backs’ – click here
- Glencore’s transfer pricing tax victory: key takeaways – click here
- How will the G20/OECD’s pillar one and pillar two project affect disputes? – click here
- 130 tax jurisdictions agree on digital economy taxation – click here
- African Tax Administration Forum responds to ‘historic’ international tax reform – click here
Romania
- NAFA has a new procedure for the tax inspection, but the elements that a team should follow when qualifying a transaction in a deed sanctioned by the criminal law are missing (RO) – click here
- SAF-T reporting, mandatory for large taxpayers from January 1, 2022. What does the implementation entail? (RO) – click here
- Tax group in the field of profit tax (RO) – click here
- Single Declaration: NAFA officials in the central area will provide assistance in the territory from January 15 to May 25 (RO) – click here
- Correct taxpayers, punished by NAFA. Did you want a bonus? Bad luck! The tax office began to seize all the accounts of those who applied bonuses in 2017 and 2018 to the submission of the Single Declaration (RO) – click here
DAC6
- Ireland updated DAC6 XML Schema to Version 1.2 – click here
- Ireland confirms new DAC6 reporting format – click here
- 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
