brought to you by TPS
Europe
- Germany: Proposed investment tax incentives, Pillar Two changes, intra-group financing transfer pricing guidance, Multilateral Instrument (MLI) law enacted – click here;
- Germany: Updated Foreign Account Tax Compliance Act (FATCA) communication manual – click here;
- Czech Republic: Proposed amendment to legislation introducing top-up tax, implementing EU directive on global minimum tax – click here;
Global
- Inclusive Framework Members make further progress in addressing harmful tax practices – click here and here;
- Public comments published on Pillar Two return XML schema and schema user guide – click here;
- OECD Releases Selection Documentation Package for the International Compliance Assurance Program (ICAP) Risk Assessments – click here;
- Global economic changes and the impact on TP from an industry perspective – click here;
- The Basel regulation’s TP implications for banking institutions: yesterday, today, and tomorrow – click here;
- Amount B in life sciences and healthcare: an industry perspective – click here;
- Developments in applying the TP risk allocation framework: technology, media and telecommunications sector considerations – click here;
- A new age of country-by-country tax transparency in the financial services sector – click here;
- How Intercompany Agreements Can Mitigate Transfer Pricing Risk – click here;
- KPMG report: Survey on application of control of risk and the Development, Enhancement, Maintenance, Protection and Exploitation of Intangibles (DEMPE) frameworks, focus on India and South Korea – click here;
- UAE: Corporate tax guide on determination of taxable income – click here;
- Macau authorises Automatic Exchange of Information (AEOI) signing with Hong Kong – click here;
Romania
- Companies, authorized individuals, individuals and other categories of taxpayers will benefit from a tax amnesty, a draft to this effect has been prepared by the Ministry of Finance (RO) – click here and here and here;
- The level of interest and penalties that NAFA will charge in case of main tax obligations not paid on time, as well as for non-declaration or incorrect declaration, will increase significantly from next year, according to a draft Government Emergency Ordinance (RO) – click here;
- Annual financial statements: the size criteria for companies have been amended by Order 4164/2024 (RO) – click here and here;
- The Government is negotiating an agreement with the European Commission to reduce the budget deficit by streamlining expenses and promises not to increase taxes from 2025 (RO) – click here and here;
- Combating tax evasion: what's new in Law 126/2024 (RO) – click here;
TP Cases
- Italy’s Supreme Court Follows OECD Guidelines on Comparables – click here;
- Belgium: CJEU issues judgement upholding validity of DAC6 provisions – click here.
