brought to you by TPS
Europe
- UK: Treasury provides update on implementation of OECD guidance on Pillar Two safe harbor – click here;
- Lithuania: Updates indicate that Lithuania has signed DPI MCAA and MDR MCAA – click here;
- Germany: Federal central tax office issues updated Common Reporting Standard “CRS” manual – click here;
- Estonia: Preliminary bill for public CbC reporting submitted to parliament – click here;
- Finland: Legislation implementing Pillar Two global minimum tax – click here;
- EU Public Country-by-Country Reporting obligations for EU-headquartered and non-EU-headquartered multinationals from 22 June 2024 – click here;
- E-News from the EU Tax Centre – click here;
Global
- United States: IRS Transfer Pricing Memo On Implicit Support Has Legal Flaws – click here;
- United States: OECD releases first set of ICAP statistics – click here and here;
- Australia initiates consultation on transfer pricing rules for petroleum resource rent tax – click here;
- Indonesia: The new Indonesian TP rule: clear path or labyrinth of doubt?– click here;
- The Latest on BEPS and Beyond | 2023 and beyond in review – click here;
- KPMG report: Amount B compliance challenges – click here;
- Transfer Pricing Disputes Under Pillar Two Demand Sharp Data – click here;
Romania
- The Constitutional Court of Romania (CCR) validates Law no. 241/2005 which saves from prison the tax evaders who have caused a prejudice of up to EUR 1,000,000, if they pay the amount plus a penalty (RO) – click here and here;
- Anti-money laundering: New rules for tax consultants and tax advisory firms have been published in the Official Gazette (RO) – click here;
- The National Council of Small and Medium-Sized Private Enterprises in Romania (CNIPMMR), the organisation that defends the interests of small and medium-sized companies, asks the Ministry of Finance to clarify the conditions under which a micro-enterprise qualifies for the payment of income tax (RO) – click here;
- The threshold for microenterprises will remain as a technical point for discussions in the evaluation of the National Recovery and Resilience Plan (PNRR) - The European Commission wants to reduce the threshold, the Romanian Government wants negotiation (RO) – click here;
- Representatives of the European Commission are visiting Bucharest between 18-21 March. Discussions on Romania's fiscal situation, payment request number 3 of the National Recovery and Resilience Plan (PNRR) and the lowering of the micro-enterprise threshold (RO) – click here;
- What chaos emerges with associates of several microenterprises: entrepreneurs can sue each other and NAFA (RO) – click here;
- Related enterprises 2024. What is the new definition and how is it implemented (RO) – click here;
- NAFA criminal complaints - at historic lows. Authorities have changed their priorities, tax evasion is no longer the number one target (RO) – click here;
- DECISION: Extension of no fine period for e-Invoice until 31st May (RO) – click here;
- The e-Invoice system is not yet finalised: there are still practical and legislative issues / Questions and answers from the NAFA webinar / Why PDF downloading is slow (RO) – click here;
- Anti-fraud inspections with the Labour Inspectorate have intensified in certain areas. E-transport and e-invoicing attract increasing fines, and information from SAF-T files will be used in inspections and documentary checks (RO) – click here;
- Starting with 2025, NAFA will have county Anti-Fraud structures / 1 May 2024: The Directorate for Large Taxpayers is absorbed by NAFA / Government Emergency Ordinance (GEO) in the Official Gazette (RO) – click here and here;
- European Commission expects Romania's tax deficit to rise to 7% of GDP in 2024 (RO) – click here;
TP Cases
- AG opines Dutch interest deduction limitation rules not in conflict with EU law – click here and here.
