Europe
- Dutch 2022 budget plan includes tax proposals on transfer pricing, hybrids – click here
- Belgian court rules against retroactive application of transfer pricing guidelines – click here
- Switzerland: Arm’s length price and transfer pricing implications of financial guarantees– click here
- Norwegian Government proposes amendments to tax rules applicable to cross-border restructurings – click here
- The Netherlands publishes draft legislation on reverse hybrid entities as final part of ATAD II implementation – click here
- LIBOR transition, transfer pricing considerations of intercompany financial arrangements – click here
- Managing transfer pricing and customs risks of cross-border transactions – click here
- Ireland has changed its mind and will support the global corporate tax. "We will sign the agreement if the conditions are met" (RO) – click here
- European Council advances directive on public country-by-country tax reporting – click here
- Poland plans to introduce tax on shifted profits – click here
- Poland considers delayed introduction of ‘hidden divided’ non-deductibility concept – click here
- Ukraine Ministry of Finance clarifies general tax consultation on deemed dividends – click here
- Ukraine advances tax treaty protocols with Denmark and Qatar – click here
Global
- Mexican government proposes new TP rules – click here
- Report on recent US international tax developments – click here
- US IRS and Treasury release 2021--2022 Priority Guidance Plan with new transfer pricing projects – click here
- Israeli Court rules on reclassification of trademark transaction between a shareholder and its company and the arm’s-length return on R&D services – click here
- India Tax Administration extends applicability of transfer pricing safe harbor rules to financial year 2020-21 – click here
- Jordan: Instructions for implementing transfer pricing regime include documentation requirements – click here
- Andorra, Namibia and Spain take further steps to strengthen their tax treaties – click here
- Australian Taxation Office reacts to loss in Glencore transfer pricing case – click here
- Australia announces expanded double tax treaty network – click here
- Global minimum tax negotiations focus on carve-outs, EU consensus, closing deal – click here
- Government to seek ‘certainty’ before signing corporate tax deal – click here
- OECD’s GloBE rules: Blending in with jurisdictional blending – click here
Romania
- The deadline of October 1 and a few things to consider in the area of taxation (RO) – click here
- Fiscal consolidation for corporate income tax can be applied from next year: Groups of companies have a deadline: November 2 (RO) – click here
- The transfer of the activity for solving the NAFA appeals to the Ministry of Finance is postponed again, until March 31, 2022 (RO) – click here
- NAFA launches anti-fraud checks on cash registers. Small and medium-sized companies still have until the end of November to connect them to the NAFA computer system (RO) – click here
- e-Invoice app debated by Finance - regulates the structure of electronic invoicing and how the system is used by companies and public institutions (RO) – 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