Europe

  • Luxembourg: Tax exemption under participation regime, beneficial ownership and withholding tax refunds (court decisions) – click here
  • Portugal: European Court of Justice decision on withholding tax applicable on dividends distributed to non-resident Undertakings for Collective Investment – click here
  • Germany: Disallowance of final losses incurred by UK permanent establishment held valid (CJEU Advocate General opinion) – click here

Global

  • OECD releases public consultation document on Extractives Exclusion under Amount A for Pillar One – click here
  • IRS practice unit: Country-by-country (CbC) report in the transfer pricing risk analysis process – click here
  • Kenya: Transfer pricing and other tax-related measures in Finance Bill, 2022 – click here
  • Kenya publishes additional regulations on beneficial ownership – click here
  • Mexico: Assessing how synergies in asset valuation affect TP compliance – click here
  • Following up on Mexican beneficial owner obligations – click here
  • Paraguay publishes rules for preparing local transfer pricing technical study report, sets deadline – click here
  • Costa Rica: Temporary relief for imports, quantification of exchange differential, ultimate beneficial owners reporting – click here
  • Chile: Instructions for mutual agreement procedure under income tax treaties, recent VAT developments – click here
  • Bolivia: Extended deadline for filing corporate income tax forms, statements – click here

Romania

  • External daily allowances and the new ceiling introduced by Law 72/2022. How are the amounts calculated for employees? – click here
  • NAFA wants to foreclose on the beverage empire of the Micula brothers. The history of the Micula case vs. the Romanian state – click here
  • Cristina Saulescu, Cabot Transfer Pricing Partner: 2022 brings new fiscal facilities – 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
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Note: Please note that TPS could not be held responsible for the content and accuracy of the information obtained by accessing these websites, nor for the consequences resulted from any activities one performs based on this information. Even though we are monitoring the outbound links, we do not have control over the availability of the information offered by external references or how often the information is updated.

Contacts

email: letstalk@transferpricing.global 

phone: 0040 742 159 142

 

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