Europe
- UK: HM Treasury publishes amendments to digital platform reporting regulations – click here and here;
- Ireland approves new global tax reform rules – click here;
- Luxembourg: Revised draft law amending Pillar Two law – click here;
- Luxembourg updates CbC reporting guidance – click here;
- Poland: Legislation implementing Pillar Two global minimum tax rules passed by upper house of Parliament – click here;
- Montenegro: Multilateral agreement on exchange of country-by-country reports – click here;
Global
- OECD released Tax Administration 2024: Comparative Information on OECD and other Advanced and Emerging Economies, a report that contains internationally comparative data on aspects of tax systems and their administration across 58 jurisdictions – click here for the summary;
- United States: Internal Revenue Service (IRS) releases draft 2025 Form 1042-S and instructions – click here;
- India: The Central Board of Direct Taxes (CBDT) issues circular answering FAQs on direct tax resolution scheme – click here;
- Australia: Lodgement deferral for Country-by-Country (CBC) reporting statements – click here;
- Australia: Public Groups disputes and settlements report insights – click here and here;
- UAE: Tax guide on corporate tax returns includes transfer pricing thresholds and procedures – click here;
- Japan: Optimizing tax operations - evolving challenges require innovative solutions (Podcast) – click here for the press release and here for the summary;
- Malaysia: Tax highlights of Budget 2025 include measures focused on broadening tax base – click here;
- Bahamas: Proposed Pillar Two legislation – click here;
- Costa Rica: Automatic exchange of information for sellers on digital platforms – click here and here;
- Armenia: Agreement on automatic exchange of country-by-country reports – click here;
- Bahrain: New income tax treaty with Guernsey; amendments to treaty with Czech Republic – click here;
- Bangladesh: National Board of Revenue (NBR) to conduct first transfer pricing audit to tackle tax evasion – click here;
Romania
- The impact of the Corporate Sustainability Reporting Directive (CSRD) in the area of Transfer Pricing (RO) – click here;
- The new Government Decision (GD) for the amendment of Law no. 227/2015. Changes regarding the profit tax and the microenterprises tax (RO) – click here;
- The Government approved a new Emergency Ordinance (GEO), containing several amendments to Law no. 227/2015 regarding the Fiscal Code. The introduction of the intelligent unique declaration (e-DU) and the elimination of the estimated income declaration (RO) – click here and here;
- NAFA received over 100,000 applications for the tax amnesty, putting employees under pressure. The Ministry of Finance is considering introducing longer terms for applying the tax amnesty, including the NAFA decision issuance period. (RO) – click here;
- The deadline for applying the tax amnesty is extended until 20th of December 2024 (RO) – click here and here;
- The Ministry of Finance proposes the extension of the deadline for applying the e-VAT fine until 30th of June, 2025; changes regarding the use of Personal Numeric Code (PNC) will be made in the e-Invoice system; a guide with types of invoices and VAT codes will be published (RO) – click here and here;
TP Cases
- UK: Tribunal dismisses taxpayer’s appeal on loan relationships “unallowable purpose” rule – click here for the press release and here for the court decision;
- Slovakia: Transfer pricing for manufacturing companies (court decisions) - Assessing the functions and risks of a company in the light of recent case law – click here;
Webinars
- Legal Issues of Webscraping and AI Tax Tools- Practical Guidance for Tax Professionals, 20th of November – click here for the agenda and here for the registration form.