Europe

  • OECD published Bilateral Advance Pricing Arrangement Manual– click here 
  • Germany: Draft legislation on submission of transfer pricing documentation in tax audit – click here
  • Belgium: Deadline for filing Local file forms is 17 October 2022 – click here
  • Irish Revenue Updates Guide to Exchange of Information Including New Section on DAC6 – click here
  • Switzerland: Tax-related information exchange with Russia suspended – click here
  • Netherland: The Dutch Minister of Finance: “To date Hungary is still blocking a Council agreement on the proposal for an EU Directive to implement Pillar 2” – click here
  • Global TP Forum Europe: Tax leaders demand ‘simplified’ pillar one – click here

Global

  • US: US IRS official reemphasizes IRS focus on penalties in transfer pricing cases– click here
  • US: Report on recent US international tax developments – 23 September 2022 – click here
  • US: This week in tax: Cisco urges investors to reject public CbCR – click here
  • Canada: CRA Transfer Pricing Memoranda On Downward Transfer Pricing Adjustments – click here
  • Canada: New proposed mandatory tax planning reporting obligations under the Canadian Income Tax Act – click here
  • South Africa: Increased transfer pricing scrutiny – click here
  • Tanzania: How intercompany recharges affect transfer pricing for firms – click here
  • Malaysia: Tax Matters – Defective transfer pricing documentation is trouble – click here
  • Derivative Nature of Certain Delineated Controlled Transactions – click here
  • TP considerations arising from remote working, digitalization, and business restructuring – click here
  • TP documentation – building a strong first line of defense against disputes – click here
  • Tax authority requests for information – managing TP evidence across your enterprise – click here
  • TP controversy: Prevention is better than cure – click here
  • Managing Tax Disputes Summit: Mismatches in global TP audits laid bare” – click here
  • ITR TP Forum: Speakers hail benefits of operational TP – click here

Romania

  • European authorities are preparing tougher regulations to reduce fraud and evasion (RO) – click here
  • NAFA has intensified its inspections. How can taxpayers find out if the inspectors are coming (RO) – click here
  • The police told NAFA "to take a walk" regarding the criminal notifications submitted in bulk for 53,000 companies (RO) – click here
  • NAFA collections in the first 8 months increased by 12.5% (RO) – click here
  • NAFA proposal: Mandatory bank account for all companies carrying out economic activities (RO) – click here
  • Central public administration will be required to provide forms that can be downloaded and completed on a computer (RO) – click here

DAC6

  • For the latest developments and news concerning DAC6 – 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/
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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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