brought to you by TPS
Europe
- Ireland: Irish Revenue makes changes to bilateral advance pricing agreement guidelines – click here;
- Slovakia: Guidelines on transfer pricing documentation for 2023 – click here and here;
- Norway: Pillar Two global minimum tax implemented in Supplementary Tax Act – click here;
- Belgium: Amendments to Pillar Two global minimum tax rules – click here;
- Belgian companies face new wave of transfer pricing audits – click here;
- Luxembourg: What is new in Luxembourg on the transfer pricing front? – click here;
Global
- OECD: Consolidated commentary on Pillar Two rules, updated Pillar Two examples – click here and here;
- OECD: Tax inspectors without borders 2024 annual report, new focus on Country-by-Country data and digital economy – click here;
- Implementing transfer pricing and tax governance in line with ESG (“Environmental, Social and Governance”) principles – click here;
- KPMG report: Employee data reporting for Public Country-by-Country reporting – click here;
- Transfer Pricing – The foundations for a sustainable tax policy In the Middle East – click here;
- Australia: Enhancing transfer pricing oversight: ANAO (“Australian National Audit Office”) reveals ATO’s strategies and recommendations – click here;
- Australia ATO introduces change to CbC local file reporting from 2025 – click here;
- US: Report on recent US international tax developments — 3 May 2024 – click here;
- Dominican Republic filing deadline approaches for Country-by-Country Report – click here;
- Mexico: Understanding Mexican PE (“Permanent Establishment”) risks from services rendered by foreign resident contractors – click here;
- India: ESOPs (“Employee Stock Option Plans”) granted by holding companies: Indian tax and transfer pricing intricacies – click here;
Romania
- NAFA has started control procedures regarding "Country-by-Country" reporting (RO) – click here;
- NAFA tightens tax inspections: Penal pressure will be higher this year (RO) – click here and here;
- Tax obligations calendar for May 2024: What are the tax obligations taxpayers have this month (RO) – click here;
- NAFA: In May, all webinars will address how to fill in and submit the Single Declaration (RO) – click here;
- NAFA published the "white list" for the first quarter of 2024 (RO) – click here;
- NAFA published the "shame list" for the first quarter of 2024 (RO) – click here;
- How multi-national entities in Romania can avoid double taxation (RO) – click here;
TP Cases
- Czech Republic: Beneficial owner of royalties under tax treaty (Supreme Administrative Court decision) – click here;
- Korea: Interest deductions could be challenged on arm’s length grounds, but not wholly denied as tax avoidance – click here.
