brought to you by TPS
Europe
- Italy: Guidance on new reporting obligations for digital platform operators (DAC7) – click here;
- Luxembourg: Amended draft law implementing Pillar Two global minimum tax – click here;
- Belgium: Draft law proposes changes to Cayman tax – click here;
- Poland: Recent corporate income tax guidance – click here;
- Albania: Source of income and permanent establishment rules for 2024 – click here;
- Greece: Guidance on VAT treatment of over the counter derivatives – click here;
- Malta: Draft legislation implementing certain VAT measures in 2024 budget – click here;
Global
- KPMG report: OECD official provides update on expected transfer pricing guidance – click here;
- KPMG report: IRS large foreign-owned transfer pricing initiative aimed at inbound distributors – click here;
- Implication of rising interest rates on the intercompany financing arrangements – click here;
- Canada: First reading of second 2023 federal budget bill includes EIFEL, hybrid mismatch, and DST rules – click here;
- Canada: Tax “fairness relief” requests related to 2013 due by 31 December 2023 – click here;
- Australia: Guidance on tax treatment of off-market share buy-backs – click here;
- Australia: Tax treaty with Portugal signed – click here;
- Saudi Arabia: Tax incentives package for regional headquarters program – click here;
- India: No obligation to withhold tax on notional income – click here;
- Philippines: Amendments to creditable withholding tax; VAT registration – click here;
- Thailand: Further guidance on foreign-sourced income brought into Thailand by Thai tax residents – click here;
- Nigeria: Full waiver of penalties and interest on outstanding tax liabilities – click here;
Romania
- Order 1946/2023: New rules have been approved for the automatic exchange of information reported by platforms Operators (RO) – click here;
- NAFA transferred almost 800 companies from the Directorate of Large Taxpayers to county tax administrations. The head of Large Taxpayers, Ionut Misa, has been seconded (RO) – click here;
- Another year and new OECD Mutual Agreement Procedure Champions. How is Romania's statistical standing this time? (RO) – click here;
- Deloitte survey: the share of multinationals estimating an increase of tax burden as a result of the implementation of the OECD reform drops to 34% from 47% last year (RO) – click here;
- The government could change the taxation regime of micro-enterprises by limiting the number of companies in which a person can be an associate or shareholder (RO) – click here;
- The e-Invoice enters into force on 1 January 2024. What you need to know (RO) – click here;
- Draft Order: financial statements for the year 2023 can be submitted by companies until May 2024. Certain expenses will have to be reported separately (RO) – click here;
- The National Institute of Statistics revises upwards the GDP for the first 9 months: the economy grew by 1.4%, not by 1.1% as previously estimated (RO) – click here;
- NAFA collected below the initial target in November, as before, but only with RON 723 million. For the whole year it could be about RON 19 billion below the RON 404 billion plan (RO) – click here;
TP Cases
- Luxembourg: European Commission erred in finding grant of State aid (CJEU judgment) – click here and here;
- Australia wins first diverted profits tax case against Pepsi – click here.
