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Europe
- Italy: Guidance on substance based income exclusion (SBIE) provisions under Pillar Two rules – click here;
- Portugal: Bill implementing Pillar Two passed by Parliament – click here;
- Poland: Proposed reforms to tax incentives system in light of Pillar Two – click here;
- Hungary: Focus on transfer pricing documentation review – click here;
- Hungary approves Country-by-Country Reporting intergovernmental agreement with the US – click here;
- Hungary: Reporting obligation of taxpayers subject to global minimum tax – click here;
- Germany: New submission deadlines for transfer pricing documentation from 1 January 2025 in Germany – click here;
- Denmark: SAF-T requirement expanded to include entities using unregistered ERP systems – click here;
- Netherlands: Letter submitted to Parliament on Pillar Two effect on Dutch tax incentives – click here;
- Latvia: Updated list of low-tax or tax-free jurisdictions – click here;
- Norway: Budget would introduce undertaxed profits rule (UTPR) from 2025 – click here;
Global
- OECD report proposes measures for international tax transparency on real estate – click here;
- Israel: Proposed "Green Track" for R&D centers – click here;
- US: Internal Revenue Service and Treasury Plan to issue guidance on streamlined approach to baseline distribution activities – click here;
- Singapore: Overview of regulations to implement Pillar Two safe harbor and transition rules – click here;
- Hong Kong: Outcomes from Pillar Two consultation – click here;
- Chile: Amendments to transfer pricing rules – click here and here;
- Trinidad and Tobago signs mutual assistance convention, Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA), and Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (CRS MCAA) – click here and here;
Romania
- Voluntary transfer pricing adjustments in the context of the tax amnesty – opportunities and compliance (RO) – click here;
- Order 6410/2024: 4 changes to the procedure for applying the tax amnesty (RO) – click here;
- The procedure for applying the tax amnesty, modified again by Order 6438/2024. What changes come into force (RO) – click here and here;
- It's official: NAFA has published the "list of shame" and the "white list" for the third quarter of 2024 (RO) – click here and here;
- The General Directorate of Anti-Fraud NAFA will send out summonses in addition to invitations / Anyone who refuses risks up to 6 years in prison (RO) – click here and here;
- What's hidden in the 2025 – 2031 Tax Plan – hints that VAT, income tax and micro-enterprise taxation will be increased (RO) – click here;
TP Cases
- Indian permanent establishment case calls for business rethink – click here;
- India: Delhi High Court upholds stability in transfer pricing: TNMM reaffirmed as preferred method – click here;
Webinars
- NAFA's webinar program this month – click here.
