brought to you by TPS
Europe
- OECD: Czech Republic, Hungary, Germany sign agreement to share digital platform income information – click here;
- European Commission issues final rules for Country-by-Country (CbC) reporting directive – click here;
- Cyprus confirms Country-by-Country (CbC) exchange effective date with US, filing obligations – click here;
- Germany: Fourth Bureaucracy Relief Act updates transfer pricing documentation requirements – click here;
- Slovenia gazettes amendments to Corporate Income Tax Law – click here;
- Ireland clarifies interest deductions for connected party loans – click here;
- Switzerland: Federal Council recommends rejecting loss carryforward time limit extension – click here;
- Poland consults updated low-tax jurisdictions list, removes Andorra – click here;
- KPMG article: Managing Italian transfer pricing audits – click here or here;
- Spain: Legislation implementing Pillar Two global minimum tax passed by lower house of Parliament – click here;
- Netherlands: Guidance on how Pillar One Amount B will affect domestic taxpayers – click here;
- Republic of Moldova: Guidance on various transfer pricing, VAT, and income tax issues – click here;
Global
- OECD: Papua New Guinea signs Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (CRS-MCAA) – click here;
- OECD: Updated International Compliance Assurance Programme (ICAP) FAQs (December 2024) – click here;
- KPMG report: Update on future of Base Erosion and Profit Shifting (BEPS) guidance from OECD – click here;
- Singapore enacts Multinational Enterprise (Minimum Tax) Act, Income Tax (Amendment) Act – click here;
- Qatar: Council of Ministers approve Pillar Two global minimum tax – click here;
- Singapore, New Zealand sign Competent Authority Arrangement on arbitration under Base Erosion and Profit Shifting Multilateral Instrument (BEPS MLI) – click here;
- India extends transfer pricing safe harbor rules to FY 2024-25, updates filing deadline for international transactions – click here;
- Australia: Parliament passes law for public Country-by-Country (CbC) reporting – click here;
- Australia: ATO updates Country-by-Country (CbC) Reporting Exemptions, adds additional compliance rules – click here;
- Australia: Parliament passes Pillar Two minimum tax bills – click here;
- Australia: Guidance on international transactions that attract scrutiny – click here;
Romania
- PwC Regional Tax Conferences: Tax changes have created a greater administrative and financial burden in FY 2024. Next year it will be even more tumultuous (RO) – click here;
- Expenditure at NAFA - RON 2 million for assessing the relationship with taxpayers (RO) – click here;
- Project: The bonus will increase from 3% to 5% for good taxpayers (RO) – click here;
- New tax changes, applicable from FY 2025. Changes on corporate, micro-enterprise and income tax (RO) – click here;
- New tax changes effective from FY 2025: from e-Invoice, rents and pensions abroad, to the Accounting Act or e-Transport. Government Emergency Ordinance (GEO), in the Official Gazette (RO) – click here;
- NAFA rejected 100,000 applications for tax amnesty / How much it has collected so far (RO) – click here or here;
- What conditions you must meet on December 31 to continue to benefit from the micro-enterprise tax as of 2025 (RO) – click here;
- Ministry of Finance, clarifications on RO e-invoice / In how many calendar days after issuing invoices must invoices be uploaded in the system, calculation example (RO) – click here;
TP Cases
- Case Commentary: Onex Corporation v. Canada, 2024 FC – click here;
Webinars
- Petruzzi Advisory: Arm’s Length Wrestling | Round 5 | United States vs Coca-Cola – December 10, 2024 – click here;
- Tax Reasonability: Myth or Reality? / January 13, 2025 – click here;
- List of webinars organized by NAFA in December 2024: from information on the Single Declaration to microenterprises – click here and here.
