brought to you by TPS
Europe
- EU: Update on direct tax initiatives, including BEPS 2.0, “Unshell,” SAFE, BEFIT, DEBRA, transfer pricing, public country-by-country reporting, FASTER, DAC7, DAC8 – click here;
- European Commission Annual Report on Taxation 2024 – click here;
- France publishes interest rate caps on shareholder loan deductions for FY ending June-September 2024 -click here;
- Italy Implements Global Minimum Taxation Under OECD’s Pillar Two Rules – click here;
- Monaco: Addition to Financial Action Task Force’s grey list – click here;
- Amending Protocol to Tax Treaty between Malta and Romania Signed – click here;
- Portugal Extends Deadline to Submit Tax Documentation File and Transfer Pricing Documentation – click here;
- UK Publishes Guidance on Preparing for the Multinational Top-up Tax and the Domestic Top-up Tax – click here;
Global
- New OECD data highlight stabilisation in statutory corporate tax rates worldwide – click here and here and for the report here;
- OECD consulting on GloBE Information Return tax user guide – click here and here;
- OECD Opens Accession Discussions with Thailand – click here and for the announcement here;
- KPMG report: Transfer pricing in Brazil – click here;
- Australia: Changes to non-arm’s length income provisions for superannuation funds – click here;
- Australia: Draft legislation implementing Pillar Two global minimum tax rules introduced in Parliament – click here;
- Australia: Legislation clarifying “exploration for petroleum,” updating transfer pricing guidance passes Parliament – click here;
- Canada: Digital services tax now in effect – click here;
- Cayman Islands: Common reporting standard (CRS) updates – click here;
- Hong Kong gazettes patent box tax incentive – click here;
Romania
- Project: Procedure for the registration in the mandatory RO e-Invoice Register. Template form 082 (RO) – click here;
- The Electronic Signature and Trust Services Act has been adopted. What are the main updates from an electronic signature perspective? (RO) – click here;
- Loans between affiliated companies: TOP 4 important aspects to consider (RO) – click here;
- Romania introduces new pre-filled VAT return requirements (RO) – click here;
TP Cases
- Czech Republic: Acquisition structure not abusive; cost base when applying net profit margin transfer pricing method – click here;
- Israel: Adjusted intellectual property (IP) valuation (District Court decision) – click here;
- The Lithuanian Tax Disputes Commission referred questions on the anti-abuse rule of the Parent-Subsidiary Directive to the CJEU for a preliminary ruling – click here;
- Advocate General Kokott answers the question whether the free movement of capital requires a Member State to treat non-resident internally managed and resident externally managed investment funds equally for tax purposes? – click here.
