Europe

  • Corporate taxation: Commission proposes tax incentive for equity to help companies grow, become stronger and more resilient – click here
  • Excluded dividends under the OECD GloBE Model Rules versus excluded dividends under the proposal for an EU Directive – click here
  • Italy: Intercompany loans in Italy: Beyond the arm’s-length principle? – click here
  • Sweden: Intra-group agreements may become a lock-in in Sweden – click here
  • Netherlands: Considerations for companies in scope of Pillar Two rules – click here
  • Czech Republic: Additional tax assessment based on overall profitability for unrelated-party transactions – click here
  • Switzerland: Transfer pricing controversy statistics, including effects of COVID-19 – click here
  • Switzerland: Federal Administrative Court judges on deductibility of management fees in real estate fund structure – click here
  • Poland: Tax effects of changing state of pandemic (COVID-19) – click here
  • Malta: FAQs on mandatory disclosure rules (DAC6) – click here and here

Global

  • OECD: Regulated financial services exclusion under Amount A of Pillar One; public consultation – click here
  • TP challenges related to comparability analysis: Impact of COVID-19 – click here
  • Emerging TP adjustments in light of COVID-19: A practical standpoint – click here
  • The rise of intangibles and the impact on TP analysis – click here
  • TP mazes and the global tax for multinational companies – click here
  • A tale of two Pillars – click here
  • Trends in TP controversies: MAPs and APAs – click here
  • Proposals to improve the efficiency of the MAP – click here
  • UN Asks For Feedback On Transfer Pricing Committee Plan – click here
  • Israel: Court decision on business restructuring and deemed transfer of business functions, assets and risks – click here
  • Israel: Changes ahead for Israel in TP, master file and country-by-country reporting – click here
  • US: Report on recent US international tax developments – 6 May 2022 – click here
  • Canada: Recent transfer pricing audit trends - CRA zeroes in on intercompany loans – click here
  • China: Challenges in implementing TP adjustments in China: Are there effective solutions? – click here
  • Vietnam: Recommended focus on tax audit and inspection of high-risk industries and areas – click here
  • Vietnam: Key TP considerations during the recovery from COVID-19 in Vietnam – click here
  • Indonesia: Death of Libor and impact on TP: Indonesian perspective – click here
  • Indonesia: Profit-linked intra-group service charges: An Indonesian perspective – click here
  • Indonesia: The promising development of APAs and MAPs in Indonesia: Part II – click here
  • Thailand: A closer look at Thailand’s TP landscape – click here
  • Brazil reinforces commitment to align its TP rules with OECD Guidelines; taxpayers requesting more clarity – click here
  • The growing prominence of marketing intangibles in TP regulations and disputes in Latin America – click here
  • New Zealand: Consultation on implementation of Pillar Two rules – click here

Romania

  • Why NAFA loses in court / Expert in tax law: Courts notice shortcomings in the interpretation of legislation (RO) – click here
  • Companies having VAT or excise duty refunds to expect tax inspections / An incredible number of inspections regarding micro-enterprises having transactions with related parties (RO) – click here
  • NAFA launches SPV applications for Android and iPhone and increases the number of tax inspections at companies. The HoReCa 2 scheme is "considered" by the Government in 2022 (RO) – click here
  • Web seminars, a new electronic service of NAFA (RO) – click here

DAC6

  • Luxembourg Updates Guidance on DAC6 Reporting with New FAQ – click here
  • 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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