brought to you by TPS
Europe
- Spain’s National Court challenges the deductibility of intragroup services in the absence of a written contract – click here
- Danish High Court rules on the application of EU Arbitration Convention and MAP in transfer pricing case – click here
- In brief: guarantees and collateral for acquisition financing in Luxembourg – click here
- Poland: Limit on tax-deductible debt financing costs (court decision) – click here
- Czech Republic: Overview of possible tax legislative changes – click here
Global
- Tax challenges arising from digitalisation: Public comments received on the draft rules for tax base determinations under Pillar One Amount A – click here and here
- The Pillar Two model rules: a train wreck in the making – click here
- International: Pillar One – Draft model rules for Tax Base Determinations published – click here
- Mexican tax reform 2022 – key topics to review from an international fiscal perspective – click here
- Costa Rica proposes allowing corporations to pay annual tax owed for tax years 2016 through 2021 on legal entities without paying interest and penalties – click here
- Thailand: Revised transfer pricing disclosure form; country-by-country reporting notification and Q&As – click here
- India: Loss from permanent diminution in value of investment in U.S. subsidiary allowable as business expenditure – click here
- Ghana: New transfer pricing regulations will address illicit financial flows – GRA – click here
- Tanzania: Transfer pricing audit: a genie in a lamp can’t save you! – click here
Romania
- Old (and new) crises reunion: the administration, the taxpayer, Hyacinth Compliance and a ticking clock! (RO) – click here
- NAFA announces that documents not yet digitized can be sent through the SPV Contact Form (RO) – click here
- Officially, carriers can rest assured: the law that "exempts" employers from paying income tax and social security contributions for drivers' per diems has been passed by Parliament. How to calculate a driver's daily allowance from now on (RO) – click here
- The government gives more flexibility to companies that help war-torn Ukrainians - they will be able to reduce their income or income tax spending if they make donations through IGSU (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
