brought to you by TPS
Europe
- European Commission publishes October 2024 infringements package – click here and here;
- European Commission ends infringement case against Germany, Hungary over DAC7 information exchange – click here;
- EU: Updated list of non-cooperative tax jurisdictions – click here and here and here;
- UK: Initial analysis of OECD’s model competent authority agreement on application of Amount B under Pillar One – click here for the press release and here for the report;
- Ukraine clarifies corporate tax rules for German entities under transfer pricing provisions – click here;
- Germany confirms completion of internal procedures for the entry into effect of BEPS MLI for tax treaties with seven countries – click here;
- Spain publishes synthesized text of tax treaty with Germany as impacted by BEPS MLI – click here;
- Italy clarifies DAC7 platform and seller definitions – click here;
- Denmark: 2024 – 2025 legislative plan proposes updates to minimum tax, transfer pricing to match OECD rules – click here;
- Montenegro: Update indicates that Montenegro has signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) – click here;
Global
- Week in insights: OECD needs to find Pillar Two's happy medium – click here;
- OECD: Model competent authority agreement on application of Amount B under Pillar One – click here;
- OECD: Working paper released on tax arbitrage through closely held businesses – click here;
- KPMG article: Impact of principal purpose test (PPT) provisions on holding companies in Latin America – click here;
- US: Treasury releases list of boycott countries – click here;
- US: U.S. chamber supports legal challenge to EU undertaxed profit rule – click here;
- Peru introduces new valuation methods for related-party transactions – click here;
- Brazil: Implementation of Pillar Two rules establishes qualified domestic minimum top-up tax – click here;
- New Zealand: Inland Revenue's 2024 multinational enterprises compliance focus – click here and here;
- Algeria signs mutual assistance convention – click here and here;
- Indonesia: Update on implementation of Pillar Two global minimum tax rules – click here;
Romania
- NAFA has published the Guide on the write-off of certain budgetary obligations (RO) – click here;
- NAFA Calendar: tax declarations due on October 25, 2024 (RO) – click here;
- The National Liberal Party's (PNL) President, Nicolae Ciuca, announces that, following the agreement received from the European Commission, the single tax rate will be maintained in 2025 and there will be no progressive tax (RO) – click here;
- SAF-T in 2024. Taxpayers that must submit the D406 (i.e. Informative Declaration on the Standard Tax Inspection File) and individuals who do not have this obligation (RO) – click here and here;
- SAF-T for small taxpayers: what are the requirements from January 1, 2025 (RO) – click here;
- The European Commission will request, in a letter to be sent to the Romanian Government on the unfulfilled milestones of the National Recovery and Resilience Plan, that the threshold for micro-enterprise tax qualification to be lowered from the threshold of EUR 500,000 per year to EUR 88,500 per year, which is currently the VAT threshold (RO) – click here;
- Multinational companies from Romania required to report their corporate income tax publicly: what rules must be followed for their first reporting, this year (RO) – click here;
TP Cases
- Slovakia: First comprehensive historical judgment on transfer pricing – click here;
- Netherlands: CJEU rules Dutch interest deduction limitation rules do not conflict with EU law – click here and here and here;
Webinars
- The transfer pricing code – navigating arm’s length rules for global intragroup financial transactions – October 23, 2024 – click here.
