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.

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