Europe

  • CFE’s Tax Top 5 – 20 January 2025 – click here;
  • Cyprus: Implementation of Pillar Two global minimum tax rules and public country-by-country reporting – click here and here;
  • The Czech Republic and Kenya conclude tax treaty negotiations – click here;
  • Lithuania: Tax treaty between Lithuania and San Marino has entered into force – click here;
  • Liechtenstein updates list of jurisdictions for CbC Report Exchange – click here;
  • Malta provides DAC6 Annual Notification Form for Non-Disclosing Intermediaries in 2025 – click here and here;
  • Poland: Tax priorities of Polish Presidency of the Council – click here;
  • Slovenia: Implementation of public country-by-country reporting – click here;
  • Ukraine updates transfer pricing rules for related parties, controlled transactions – click here;
  • Ukraine Notifies Syria of tax treaty termination – click here;

Global

  • OECD releases tools to administer global minimum tax – click here;
  • New OECD guidance addresses Pillar Two incentives and administration – click here;
  • Transfer pricing issues: tax certainty, tax uncertainty, and the International Compliance Assurance Programme (“ICAP”) – click here;
  • Australia: Legislation providing details on computation of top-up tax under Pillar Two rules – click here;
  • Australia: New transfer pricing guidance on inbound related-party funding for property and construction – click here;
  • Australia publishes synthesized text of tax treaty with Papua New Guinea as impacted by the BEPS MLI – click here;
  • Cambodia issues transfer pricing rules from 2025 – click here;
  • Hong Kong introduces 15% global minimum tax: key insights for businesses – click here;
  • Malaysia: Transfer pricing guidelines and audit framework for 2024 – click here;
  • South Africa: Legislation implementing Pillar Two global minimum tax rules enacted – click here;
  • Sri Lanka publishes new Advance Pricing Agreements guide – click here;
  • Singapore: The Inland Revenue Authority of Singapore (“IRAS”) updates 2025 transfer pricing guidance, lowers indicative margin for related-party loans – click here;
  • Thailand: Law implementing Pillar Two global minimum tax rules published – click here;
  • US: Relationship between arm’s length standard and specific period adjustment rules in section 482 regulations – click here;
  • US: White House announcement on OECD “Global Tax Deal” – click here and here and here;

Romania

  • Update of NACE rev. 3 codes: NAFA clarifications for companies (RO) – click here;
  • Clarifications on reporting form for public country-by-country disclosures (RO) – click here;
  • National Trade Register Office: Entrepreneurs must update their activity codes to NACE Rev. 3, even if there is no deadline or penalties. Sole proprietorships (PFA) can have a maximum of five NACE codes (RO) – click here;
  • Taxes 2025: e-SAF-T, e-Invoice and e-VAT rewrite the rules of tax inspections (analysis) (RO) – click here;
  • SAF-T. What fines apply to small taxpayers who DO NOT submit D406 starting from January 2025? (RO) – click here;
  • Pole tax: The forms that some taxpayers have to fill in will be updated (NAFA project) (RO) – click here;
  • The Ministry of Finance published a draft ordinance amending Law No. 227/2015 regarding the Tax Code, regulating the additional tax for legal entities operating in the oil and natural gas sectors (RO) – click here and here;

TP Cases

  • India’s Income Tax Appellate Tribunal (“ITAT”) rules on principal purpose test in India-Luxembourg tax treat – click here.

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