brought to you by TPS
Europe
- Belgium further aligns Pillar Two legislation with OECD's Agreed Administrative Guidance – click here;
- Switzerland: Cantonal tax law changes in response to Pillar Two global minimum tax – click here;
- France: Tax Authority updates interest deduction rates for shareholder loans – click here;
- Cyprus: Additional clarifications issued with respect to transfer pricing rules – click here;
- Germany: Law implementing MLI passed by lower house of Parliament, other tax developments – click here and here;
Global
- Malaysia’s Revised Income Tax Transfer Pricing Rules 2023: Implications and Compliance Measures – click here;
- The Group of 7 stated that in June it is expected to be signed a global convention on corporate taxation – click here;
- The Latest on BEPS and Beyond | May 2024 (EY) – click here;
- Guidance on the Implementation of Country-by-Country Reporting: BEPS Action 13 – updated May 2024 – click here;
- Designing a National Strategy against Tax Crime – click here;
- Statement by the Co-Chairs of the OECD/G20 Inclusive Framework on BEPS – click here;
- 2024 Progress Report on Tax Co-operation for the 21st Century – click here;
Romania
- NAFA published the Romanian translation of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (i.e. OECD Guidelines, Editions 2010, 2017 and 2022) (RO) – click here to read the press release and here;
- The last day for submitting the annual financial statements for companies was Wednesday – May 29 (RO) – click here;
- The reorganization of NAFA has been completed. “Tax inspections will be carried out at any time” (RO) – click here;
- EY analysis: Tax policies and fiscal controversies – what should companies consider during 2024 (RO) – click here;
- Loan between two companies: fiscal implications and the accounting monograph aspects regarding the waiver of the loan repayment (RO) – click here;
TP Cases
- UK: Complex Borrowing and Group Structures – click here;
- France: France vs Willink SAS, May 2024, CAA Paris (remanded) – click here;
- Sweden: Administrative Court of Appeal rules on control over risk in transfer pricing case – click here;
- India: Taxation of foreign branch at higher rate not prevented by non-discrimination article of treaty (High Court decision) – click here;
Webinars
- The Forum on Economic and Fiscal Policy, June 24 – click here;
- National Conference on Taxation and Accounting, July 2, 2024: all about e-Invoice, e-Transport, micro tax and other tax news – click here.
