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Europe
- Ukraine excludes 41 states and adds 9 to list of countries subject to transfer pricing law – click here;
- Bulgaria: Proposed mandatory use of SAF-T report – click here;
- Greece: List of noncooperative jurisdictions for FY 2023 issued – click here;
- North Macedonia: Parliament adopts law implementing Pillar Two global minimum tax rules – click here;
- Poland sets base and margin rates for transfer pricing – click here;
- Poland: Updated list of countries and territories applying harmful tax competition – click here;
- Belgium: Guidance on new controlled foreign company rules – click here;
- Luxembourg implements OECD’s Pillar Two: global minimum tax in focus – click here;
- Luxembourg: Overview of tax measures for 2025, including amended Pillar Two law – click here;
- France updates guidelines on royalties declaration under DAC7 – click here;
- UK: KPMG article: Examination of UK’s “one-way street” transfer pricing rule – click here;
- Ireland: Tax measures in Finance Bill 2024 include Pillar One Amount B rules, amendments to Pillar Two rules – click here;
- Ireland: Application of Pillar Two global minimum tax rules to fund vehicles and securitization entities – click here;
- Spain approves Pillar Two legislation – click here;
- Malta: DAC 6 - Annual Notification Form to be submitted by non-disclosing intermediaries – click here;
Global
- Editor’s picks: top ITR stories of 2024 – click here;
- Pillar One of global tax reform faces a tipping point in 2025 – click here;
- OECD Pillar One: Amount B documents published – click here;
- US Amount B Notice is transfer pricing safe harbor with caveats – click here;
- US: KPMG article: Commensurate with income standard in transfer pricing – click here;
- Australia: Pillar Two legislation enacted – click here;
- Dominican Republic Tax Administration grants automatic extension for filing Country-by-Country Reports (CbCR) – click here;
Romania
- End-of-year tax changes: Government Emergency Ordinance no. 156/30.12.2024 (RO) – click here to read the legislation and here and here for the articles;
- Klaus Iohannis, Romania's president, challenges the tax amnesty ordinance before the Constitutional Court of Romania: the law allowed for up to 50% debt reduction (RO) – click here;
- National Trade Register Office procedure and forms for updating NACE Rev.3 codes for companies and authorized individuals starting with January 1, 2025 (RO) – click here;
- NAFA will introduce chatbot technology and an audio-video communication platform for taxpayer relations (RO) – click here;
- The Ministry of Finance has published a draft Order on issues related to the preparation and submission of annual financial statements and annual accounting reports of economic operators to NAFA (RO) – click here;
TP Cases
- Romania: VAT and Transfer Pricing: the European Court of Justice brings important clarifications – click here;
- Portugal: Relatedness determined on transaction date; improper rejection of transfer pricing method (Supreme Administrative Court decisions) – click here;
- Sweden: The right to judicial review of claims for corresponding adjustments – click here;
- Germany: Transfer prices for parallel imports under revision – click here;
- Denmark: Taxpayer prepared adequate transfer pricing documentation and related party payments were arm’s length (Supreme Court decision) – click here and here;
Webinars
- List of webinars for January 2025 published on NAFA's portal – click here;
- Transfer Pricing trends for 2025: navigating the future of compliance and strategy: January 22, 2025 – click here.
