brought to you by TPS
Europe
- European Finance Ministers adopt new reporting and exchange of information rules centered around crypto-assets – click here;
- Germany: Losses of permanent establishments in other EU countries not deductible (Federal Tax Court decision) – click here;
- Switzerland opens public consultation on procedural aspects of the OECD's Pillar Two minimum corporate tax – click here;
- Czech Republic: Implications for Czech taxpayers of updates to EU noncooperative jurisdictions list – click here;
- Albania: New law on income tax significantly amends corporate, individual, and withholding tax – click here;
- Isle of Man: Joint statement on OECD Pillar Two global minimum tax released – click here;
Global
- Enhancing the Advance Pricing Agreement Process: APMA’s New Guidelines – click here;
- Pillar Two: Implications for harmful tax competition and profit shifting – click here;
- BEPS Action 5: Neutralizing IP-based harmful tax practices – click here;
- KPMG report: Practical transfer pricing compliance in a complex world – click here;
- KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on United States and UK – click here;
- BVI: Economic substance guidance for entities claiming tax residence in Jersey, Guernsey, or Isle of Man – click here;
- The U.S. House Committee on Ways and Means has launched an attack on Pillar 2, more specifically on the introduction of the UTPR by third countries – click here;
- US: Proposed regulations terminate section 367(d) application to certain repatriated IP – click here;
- Guatemala: Potential amendments to transfer pricing rules could increase certainty for taxpayers – click here;
- Hong-Kong: Public consultation on company re-domiciliation regime launched – click here;
- Korea: Software installation fee is royalty subject to withholding tax under income tax treaty (Tax Tribunal decision) – click here;
- Vietnam deposited its instrument for the ratification of the Multilateral BEPS Convention – click here;
- New Zealand to adopt the OECD GloBE (Pillar Two) rules – click here and here;
- Australian Taxation Office issues second draft of compliance guidelines on intangibles arrangements – click here;
Romania
- Filip & Company obtains double confirmation on the legality of voluntary transfer pricing adjustments at the HCCJ (RO) – click here and here;
- Reconstitution of lost or destroyed accounting documents is MANDATORY if they are within the 5-year retention period (RO) – click here;
- Documenting the relationship between manufacturer and retailer – a necessary red tape? (RO) – click here;
- Shocking move at the top of NAFA: head of NAFA Lucian Heiuş has resigned. The budget execution was published today, showing that net VAT revenues collapsed in April (RO) – click here;
- NAFA: We have been sending the Compliance Notice to taxpayers for a month now (RO) – click here;
- The Body of Expert and Licensed Accountants of Romania requests the extension of the deadline for submitting the 2023 tax returns after the NAFA website did not work in the last few days (RO) – click here;
- NAFA - DECISION for delays in submitting tax returns (RO) – click here;
- NAFA calendar June 2023 - deadline for submitting tax returns (RO) – click here;
- NAFA prepares regularization procedure for companies that have redirected too much of their income tax/microenterprise income tax (RO) – click here;
- Procedure for fiscal reclassification of daily allowance: NAFA, obliged to consult the Territorial Labor Inspectorate before carrying out fiscal inspection in this area (RO) – click here;
- Only a few days until SAF-T submission regarding assets. Important aspects that companies need to consider for SAF-T reporting (RO) – click here and here;
- ROeID, the application that digitizes Romania. Taxes paid with a few clicks and documents obtained online (RO) – click here;
DAC6 and DAC7
- UK: Update on mandatory disclosure rules (DAC6), now effective – click here;
- Release of the 2023 Guidelines on Mandatory Disclosure Rules (DAC6) – click here;
- EU reporting requirement for platform operators – state of play of domestic implementation of DAC7 (update as at May 2023) – click here;
- Spain: Bill implementing DAC7; VAT, income tax, and FATCA implications for finance and insurance industries – click here.
