Europe

  • The European Commission has sent letters of formal notice to Member States who have failed to notify national measures transposing tax directives – click here;
  • Germany and Luxembourg announce transitional rules for digital platform reporting obligations under DAC7; other countries retain January 31st  2024 reporting deadline – click here;
  • Spain: Several corporate tax law measures declared unconstitutional (Constitutional Court decision) – click here;
  • Albania: Withholding tax and double tax treaties applications – click here;
  • Sweden: Interest deductions incurred to finance intra-group share acquisition allowed – click here;
  • Transfer Pricing and Diverted Profits Tax statistics 2022 to 2023 – click here;

Global

  • OECD: Update of Estimated Revenue Gains from Pillar Two – click here;
  • Deloitte Partner Raises Detailed Concerns Over OECD's Proposed Permanent Establishment Threshold – click here or here;
  • Colombia: New deadlines for transfer pricing documentation – click here;
  • Australia: Practical compliance guideline on intangibles arrangements – click here;
  • KPMG report: Resurgence of transfer pricing penalties – click here;
  • IRS issues long-awaited guidance on implicit support recognition for intercompany loan transactions – click here;

Romania

  • e-Transport becomes mandatory for several categories of transport. What’s new in applying the system? (RO) – click here
  • PwC Romania Tax Talks: SAF-T in a new phase - simply submitting the declaration is no longer sufficient, NAFA will check whether the data reported by companies are correct (RO) – click here;
  • How will "Pillar 2" on the global minimum tax change transfer pricing? (RO) – click here;
  • The Minister of Finance Marcel Bolos, about tax inspections in 2024: NAFA’s actions will be targeted, not blind. Who is being taken into account (RO) – click here;
  • Accountants call on NAFA and Ministry of Finance not to issue fines / Reason: SPV malfunctions and non-recognition of electronic signatures (RO) – click here;
  • e-Invoice / NAFA recommendation: Enter your invoices in the system until March 31st / What are the penalties? (RO) – click here;
  • NAFA e-Invoice Webinar: taxpayers left high and dry / Some questions and answers: from homeowners' associations to invoices with zero or those received erroneously (RO) – click here;
  • Another day in which the NAFA website frequently displays "maintenance", to the despair of taxpayers who need to use e-Invoice (RO) – click here;
  • The Minister of Finance: We are considering postponing the April 1st date from which e-Invoice fines are applied. Depends on how taxpayers comply (RO) – click here;
  • NAFA - host of a visit of the State Tax Service of the Republic of Moldova (RO) – click here;
  • NAFA proposes to amend Form 107. What the declaration looks like and what are the instructions for completing it (RO) – click here;
  • The Ministry of Finance announces improvements for RO e-Invoice: duplicate invoices can no longer be entered (RO) – click here;
  • NAFA: 10% of large companies have not complied with SAF-T application / Contraventions to follow in the next period (RO) – click here;
  • Sponsorship of NGOs: Companies paying corporate tax will have to file a declaration on NAFA (RO) – click here;

Webinars

  • Webinar: Transfer Pricing Valuation in the BioPharma Industry – click here;
  • e-Invoice 2024: Two more webinars organised by the Ministry of Finance and NAFA in February – click here;
  • National Tax and Accounting Conference, February 24, 2024: legislative changes and their implications for your business at the beginning of the year – click here;

TP Cases

  • South Africa: Interest incurred by investment holding company held non-deductible (High Court decision) – click here;
  • Dutch Court Imposes €107 Million Fine and Back Taxes on British American Tobacco – click here.

 

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Contacts

email: letstalk@transferpricing.global 

phone: 0040 742 159 142

 

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