brought to you by TPS
Europe
- Malta: Formal transfer pricing rules published – click here
- UK: Autumn statement includes transfer pricing documentation changes, update on implementation of Pillar Two, increases in corporation tax and DPT rates – click here
- UK: The TP/Customs Saga continues: new valuation guidance issued by UK Customs– click here
- Spain, Ireland fastest in closing MAP cases under tax treaties – click here
- Hungary: Amendments on DAC7 reporting requirements for platform operators – click here
- France: Electronic platforms: The DAC 7 Directive is transposed with an effective date of 1 January 2024 for transactions carried out in 2023 – click here
Global
- OECD publishes latest corporate tax statistics – click here and here
- OECD: Mutual agreement procedure (MAP) statistics for 2021 – click here
- MNEs shift profits to low-tax jurisdictions despite BEPS: report – click here
- Administrative Mechanism In India For Valuation Of Related Party Imports - Perspective & Challenges – click here
- Korea: NTS addresses double taxation problems– click here
- Korea: Transfer pricing adjustments with respect to subsidiary loan and subsidiary performance guarantees affirmed – click here
- Nigeria: A case for Nigeria to implement Advance Pricing Agreements in 2023 – click here
Romania
- NAFA President: No taxpayer should be caught in a tax inspection without a well-made risk analysis (RO) – click here
- NAFA will not start tax inspections at entities that will correct their problems. Taxpayers will have two opportunities to do so (RO) – click here
- NAFA sees risks of compliance with freelancers, income from rents and investments - It is going to take action and start controls (RO) – click here
- NAFA President: In 2023 there will be no change to the Fiscal Code (RO) – click here
- Declaration regarding the real beneficiary. The form should be submitted yearly or only when changes occur? (RO) – click here
- Companies that will no longer meet in 2023 the conditions regarding micro-enterprise classification will switch to the payment of the profit tax during the year (RO) – click here
- Proposal: The mandatory period for archiving accounting registers and supporting documents will be reduced from 10 years to 5 years (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/
