brought to you by TPS
Europe
- The European Commission Vows to ‘Bring Structure to Chaos’ with Transfer Pricing Directive – click here;
- CFE Tax Advisers Europe: Opinion Statement FC 5/2024 – Evaluation of the EU Anti-Tax Avoidance Directive (ATAD) – click here for the press release and here for the document;
- Germany: the German Ministry of Finance (MOF) issues draft transfer pricing guidance for intercompany financing arrangements – click here;
- United Kingdom: HM Revenue & Customs (HMRC) consults on further draft Pillar Two guidance – click here;
- The Netherlands: The Dutch Ministry of Finance publishes tax plan for 2025 – click here and here;
- Switzerland updates list of jurisdictions under Multilateral Competent Authority Agreement (MCAA) for country-by-country (CbC) reporting – click here;
- Italy issues decree on public country-by-country (CbC) reporting – click here;
- Sweden: Proposed amendments to Pillar Two global minimum tax rules – click here;
- Finland: Consultation on proposed amendments to Pillar Two global minimum tax rules – click here;
- Albania: Country-by-country reporting legislation implemented – click here and here;
Global
- OECD: New treaty advances Pillar Two global minimum tax Subject to Tax Rule designed to protect tax bases in developing countries – click here;
- OECD/G20 Inclusive Framework on BEPS shows progress in making dispute resolution more effective and in improving tax transparency through Country-by-Country reporting – click here;
- OECD: Template released for International Compliance Assurance Programme (ICAP) outcome letters – click here;
- OECD: First reports resulting from BEPS action 14 simplified peer review process released – click here;
- OECD: Annual peer review of BEPS Action 13 minimum standard on country-by-country reporting – click here and here for the press releases and here for the report;
- United States: House Republican leadership, Ways and Means members express opposition to Pillar Two deal in letter to OECD – click here for the press release and here for the document;
- Russia: Federal Tax Service (FTS) issues new transfer pricing reporting requirements – click here;
- Turkey updates country-by-country (CbC) reporting deadline – click here;
- Peru: Import and export of commodities subject to transfer pricing regulations – click here and here;
- Egypt: Overview of changes to permanent establishment provisions – click here;
- Egypt: OECD Report on Simplified Peer Review of Egypt under BEPS Action 14 – click here;
- Nigeria: OECD Report on Simplified Peer Review of Nigeria under BEPS Action 14 – click here;
- Kenya: Parliament approves the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI) – click here;
Romania
- Fiscal Gazette: Essential fiscal news published between August 25 and September 10 (RO) – click here;
- The Chamber of Fiscal Consultants (CFC) organizes an admission exam for the profession of tax consultant or assistant tax consultant - Session of November 9th, 2024 (RO) – click here;
- Details about the admission exam organized by The Body of Expert and Licensed Accountants of Romania (RO) – click here and here;
- The Ministry of Finance proposes the extension of fiscal incentives for investments in research and development activities (RO) – click here and here;
- The state is not able to collect RON 37.4 billion expected from VAT, but hopes that the e-VAT will solve the problem starting with 2025 – click here; Also, guides regarding the pre-filled RO e-VAT statement and the e-Transport Application are available - click here and here; Clarifications and postponement of certain deadlines for 'RO e-VAT compliance notification' issued (RO) - click here;
- Project: The amnesty application procedure introduced by The Government Emergency Ordinance (GEO) 107/2024 (RO) – click here and here;
- Tax amnesty: The steps you must follow to benefit from the tax facilities (RO) – click here, and here;
- More than 5,000 companies in Romania must prepare sustainability reports in 2025-2026. What do these reporting requirements entail? (RO) – click here;
TP Cases
- United Kingdom: European Commission’s finding of unlawful State aid annulled, judgment of General Court set aside (Court of Justice of the European Union judgment) – click here and here;
- Ireland: The Court of Justice of the European Union (CJEU) overturns General Court ruling in Irish state aid case – click here;
Webinars
- Arm’s Length Wrestling | Round 4 | European Commission vs Ireland and Apple, October 22nd, 2024, 4:00 PM - 5:00 PM GMT+3 – click here for the press release and here for the registration form;
- TPA Global: Building Awareness with your Tax Team on the Digital Transformation Journey, September 25th, 2024, 16:00 – 17:00 CET – click here for the press release and here for the registration form.
