brought to you by TPS
Europe
- This week in tax: UK companies paying more tax ‘since the 1970s’ – click here;
- Poland: Guidance on transfer pricing cost-plus method – click here;
- Czech Republic: Deadline for filing additional tax return for lower tax (Supreme Administrative Court decision) – click here;
- Cyprus issues draft legislative proposal on Pillar Two global minimum tax – click here and here and here;
- Ireland: Tax proposals in budget 2024 – click here;
Global
- OECD: Minimum tax implementation handbook (Pillar Two) – click here;
- Multilateral convention to implement Amount A of Pillar One; implementation handbook for Pillar Two global minimum tax – click here;
- OECD/G20 Inclusive Framework releases new multilateral convention to address tax challenges of globalisation and digitalisation – click here;
- Transfer pricing brief: October 2023 – click here;
- Jersey: Key tax aspects of proposed government plan 2024 - 2027 – click here;
- United States: Treasury request for public input on OECD multilateral convention to implement Amount A of Pillar One – click here;
- KPMG report: Mexican-sourced technical assistance payments subject to withholding tax under Netherlands treaty – click here;
- Costa Rica: Tax compliance obligations for dissolved entities – click here;
- Bermuda: Second public consultation related to proposed corporate income tax – click here;
- Bahamas: Updated FATCA and CRS reporting deadlines – click here;
Romania
- NAFA clarifications regarding evolution of the number of large taxpayers (RO) – click here and here;
- Tax inspections. What deficiencies regarding the application of tax legislation did the inspectors identify in the first semester of 2023 (RO) – click here;
- Fiscal measures for 2024. Ministry of Finance is preparing a series of measures for the reform of NAFA, also targeting the category of large taxpayers (RO) – click here;
- A new package of fiscal measures will be discussed in the near future (RO) – click here;
- Direct fine for taxpayers who do not submit tax returns on term or do not comply with cash register legislation (RO) – click here;
- NAFA calendar: The list of the main tax returns for November 2023 (RO) – click here;
- Interview with the Minister of Finance: We already have a deficit of RON 20 billion on budget revenues (RO) – click here;
- Another good month for the state budget, after the collapse in the first months of the year: Revenues speed-up with 20% and expenses slow down with 10% in August (RO) – click here;
- NNDKP Legal & Tax, 8th edition - Monday, October 16, from 10 AM on zf.ro: Are the tax increases enough or is another wave coming? What can we expect in 2024? (RO) – click here;
- NAFA restructuring is coming: Ionut Misa's directorate will be decentralized / Major cases of tax evasion will be managed by the competent bodies (RO) – click here and here;
- Tax benefits that Romanian companies can take advantage of. "Their application would have a major contribution to the optimization of financial flows and fiscal consolidation of businesses in Romania." (RO) – click here and here;
- NAFA management wants to move, in the year of the elections, 1,000 large companies from the Directorate of Large Taxpayers to the county treasury administrations. There is a risk that these companies will end up as contributors to the money box of the parties (RO) – click here;
- The latest changes to the Fiscal Code discussed at the National Tax and Accounting Tournament organized by Rentrop and Straton (RO) – click here;
CbCR
- OECD releases outcomes of sixth peer review on BEPS Action 13 on country-by-country reporting – click here;
DAC6 & DAC7
- French tax authorities update DAC 6 guidelines regarding exchange of information hallmark – click here;
- DAC 7 implementation begins to take shape. NAFA published the reporting form and a procedure for verifying the operators – click here;
TP Cases
- S. Internal Revenue Service audit finds Microsoft owes nearly $29 billion in taxes; company plans to appeal – click here and here;
Webinars
- Understanding Country-by-Country Reporting – 18 October 2023 | 4 PM – click here;
- 27th Session of the Committee of Experts on International Cooperation in Tax Matters – 17 to 20 October 2023 – click here;
- EU tax symposium 2023 "The future of taxation in the EU: challenges ahead and changes needed" – 24 to 25 October 2023 – click here.
