brought to you by TPS
Europe
- Euro Tax Flash from EU Tax Centre – click here;
- Infringement proceedings opened for failure to communicate directives' transposition – click here;
- Swiss Tax Administration Issues Transfer Pricing Guidelines – click here;
- 2024 Swiss safe harbour interest rates for intra-group loans – EUR and GBP rate decreased, USD rate increased – click here;
- A platform for reform: the UK’s international tax proposals – click here;
- UK: Other news in brief – click here;
- UK: Updated transfer pricing guidance on allocation of risk in controlled transactions – click here;
- Malta Amends Grandfathering Provision for New Transfer Pricing Rules and Issues Guidelines – click here;
- Germany: Final guidance on CFC rules, other tax developments – click here;
- Germany: Tax authority extends time limit for DAC7 reporting – click here;
- Poland: Procedure for filing transfer pricing reporting forms for acquired entities – click here;
Global
- Pillars one and two: TP considerations for jurisdictions and MNEs – click here;
- TP experts warn of possible tax rate instability – click here;
- OECD publishes ICAP statistics – click here and here;
- KPMG report: Europe, Middle East, and Africa (EMA) transfer pricing insights (February 2024) – click here;
- Australian Tax Office issues updated draft taxation ruling TR 2024/D1 on software royalties – click here;
- Australia: Guide on hybrid mismatch rules; new case studies on offshore tax evasion – click here;
Romania
- NAFA moves more than 1,000 companies from large taxpayers to its regional general directorates, leaving the large taxpayers directorate with only 1,424 taxpayers, the lowest level since 2008 (RO) – click here and here;
- False messages on behalf of NAFA (RO) – click here;
- Over RON 8 million in fines imposed during anti-fraud inspections conducted in January 2024 (RO) – click here;
- Horizontal monitoring: From 1-15 February large taxpayers can apply for the project that will solve their tax problems in real time (RO) – click here;
- The Ministry of Finance announces improvements to the e-Invoice system. Self-invoicing was introduced (RO) – click here;
- e-Invoice: Marcel Bolos considers postponing the start date for the application of fines and penalties (RO) – click here;
- Starting with 2024, large and medium sized companies have to prepare a sustainability report that will replace the previously related non-financial statement which will no longer be filed (RO) – click here;
- Ministry of Finance: results of NAFA's actions in 2023. Undeclared tax liabilities of RON 10.62 billion were identified. In which industries were the most problems found? (RO) – click here;
- IMF report after their visit in Bucharest. The package regarding the tax measures approved by the Government last year was a step in the right direction and creates additional revenues, but, over the next years, Romania will have fiscal deficiencies of over 6% of GDP considering the costs of the new pensions law (RO) – click here;
- NBR: Inflation will rise at the beginning of the year and further tax increases are not excluded given the budgetary constraints (RO) – click here;
- The Government closed 2023 with a deficit of 5.68% of GDP (RO) – click here;
Webinars
- Transfer Pricing Valuation in the BioPharma Industry, 7 February 2024 – click here;
TP Cases
- RO: The High Court of Cassation and Justice has given a landmark ruling for the industry that buys recycling/recovery services for packaging waste and for clarifying important transfer pricing issues – click here;
- UK: Upper Tribunal rules on what constitutes valid double tax relief claim – click here.
