brought to you by TPS
Europe
- Spanish National Court challenges the application of an internal CUP in favor of the TNMM – click here
- Italy issues final guidance on hybrid mismatches – click here
- Swiss withholding tax and stamp duty reform strengthens the debt capital market – click here
- The applicability of the Spanish GAAR to conduit structures after the CJEU Danish cases – click here
- Italy: Luxembourg fund exempt from withholding tax on Italian dividends; refund opportunities (court decision) – click here
Global
- OECD Tax Talks’ presentation slides – click here
- The Netherlands and Colombia have signed an agreement for smooth trade – click here
- Netherlands: Update on 2022 tax treaty negotiations with (among others) Morocco, Mozambique, Uganda and Rwanda – click here
- Kenya: embracing the two-pillar approach – click here
- Singapore studying ‘top-up’ corporate tax in response to new global minimum tax rate – click here
- Has the Indian tax administration removed the sheen from the ‘most favoured nation’ clause in its tax treaties? – click here
- Hong Kong announces plans to implement BEPS 2.0, introduce 15% domestic minimum tax for in-scope MNCs from 2024-25 – click here
- Thailand signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS – click here
- Intercompany Loan Transactions: Recent Developments in South Korea’s Transfer Pricing Regime – click here
- Technology transforms TP search strategy – click here
- Apple v. European Commission: Losing the War on Corporate International Transfer Pricing - click here
Romania
- PwC Romania Annual Tax Conference: NAFA starts controls on the labor market and aims to complete 3 major digitization projects in 2022, and the tax system will be analyzed in the context of PNRR (RO) – click here
- Romania approves changes to advance tax ruling program. At the same time, the direction in charge of solving tax appeals is transferred from NAFA to the Ministry of Finance (RO) – click here and here
- webPR: Deloitte Romania and Reff & Asociații obtained a final victory in front of the HCCJ which obliges the tax authority to motivate the change of the transfer pricing method compared to the one chosen by the taxpayer (RO) – click here
- 2022 - E-invoice, SAF-T, E-transport – priorities with direct impact in VAT collection (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
