Europe
- CFE’s EU Tax Policy Report – Semester II 2021 – click here
- UK seeks feedback on revised uncertain tax treatment guidance – click here
- Poland transfer pricing laws under review to strengthen system against tax evasive behaviour – click here
- Poland: Individual ruling is not equal to APA (court decision) – click here
- Switzerland plans to implement OECD minimum tax rate for large multinational companies from 2024 – click here
- Croatia: Corporate profit tax interest rate on loans between related parties – click here
- Belgian court rules on application of tax general anti-abuse provision – click here
- Finnish R&D study supports use of tax incentives to spur growth – click here
- EU’s path forward on global minimum tax is under debate – click here
- Italy vs BenQ Italy SRL, March 2021, Court of Cassation, Sez. 5 Num. 1374 Year 2022 – click here
- Italy vs Burckert Contromatic Italiana S.p.A., November 2021, Court of Cassation,, Sez. 5 Num. 1417 Year 2022 – click here
Global
- OECD releases latest edition of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations – click here
- Montenegro: New transfer pricing rules – click here
- Korea enacts 2022 tax reform bill – click here
- Taiwan highlights changes in new tax treaty protocol with UK – click here
- Hong Kong: What does the latest pillar two rules mean for businesses in Hong Kong SAR? – click here
- Colombian regulation addresses ultimate beneficial owner report for tax purposes – click here
- Australia: Australian Federal Court judgment against singtel in Transfer Pricing dispute – click here
Romania
- Intra-group services: Why are they easily challenged by tax authorities? What can companies do? (RO) – click here
- Multinational taxation will be implemented by Romania in 2023 (RO) – click here
- Taxation of multinationals. Secretary of State: We will have a positive budgetary impact following the application of this additional charging mechanism / we will see how an increase of 5% will affect us from the competitiveness perspective (RO) – click here
- Becaming a big taxpayer: What's next? (RO) – click here
- Reorganization of the Ministry of Finance: A new direction will be created at the level of NAFA: School of Taxation / Settlement of Appeals will move to the Ministry of Finance / Customs will be separated from NAFA (project) (RO) – click here
- Tax changes discussed - Ministry of Finance: Limiting the number of microenterprises per individual, revising their taxation, reorganizing the institution, e-invoice - B2B extension (RO) – click here
- Ministry of Finance: The microenterprise area should be related to the high added value. I asked NAFA to initiate checks on companies with a negative history (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