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Europe
- OECD: Central record of Pillar Two legislation with transitional qualified status updated, OECD includes Guernsey and Spain on updated list of “qualified” jurisdictions regarding the local implementation of the Pillar Two global minimum tax rules – click here and here for the press releases and here for the Record as of 31st of March;
- EU: CFE’s Tax Top 5 – 31 March 2025 and CFE Connect – March 2025 – click here and here;
- EU: Commissioner outlines EC tax priorities at 2025 EU Tax Symposium, including commitment to Pillar Two – click here;
- France: Interest paid to shareholders: First 2025 quarterly interest rate limit established – click here;
- UK: Beyond the bank: The impact of global information reporting (GIR) on non-financial businesses – click here;
- UK: Lists of jurisdictions with qualifying income inclusion rules and domestic top-up taxes under Pillar Two rules – click here;
- UK: 2025 Finance Act enacted, includes changes to UK Pillar Two rules – click here;
- Switzerland: Key topics in cost-based transfer pricing models – click here;
- Switzerland: Switzerland updates Multilateral Competent Authority Agreement (MCAA) for the exchange of country-by-country reports (CbCR) participation list, adds Dominican Republic, Trinidad and Tobago, Vietnam – click here;
- Germany: Tax authorities update guidance on application of anti-treaty shopping rules – click here;
- Germany: Transfer pricing documentation requirements for extraordinary business transactions in 2025 – click here;
- Germany: Germany introduces revised rules for interest deduction limitations – click here;
- Spain: Regulations under Pillar Two global minimum tax law – click here;
- Bulgaria: Amendments to Pillar Two law enacted - click here;
- Finland: Guidance on Pillar Two global minimum tax – click here;
- Ukraine: State Tax Service highlights possibility of concluding Advance Pricing Agreement (APA) – click here;
- Ukraine: Ukraine issues guidance on Country by Country (CbC) reporting for US parent multinationals – click here;
Global
- OECD: KPMG report - Overview of topics and workstreams discussed at recent meeting of UN Tax Committee, including the digitalized economy, extractive industries, transfer pricing, and the taxation of cryptoassets – click here for the press release and here for the report;
- United States: the US Internal Revenue Service (IRS) released the advance pricing agreement (APA) annual report covering the activities of the Advance Pricing and Mutual Agreement (APMA) Program during calendar year 2024; The report shows decline in APA executions and completion times in 2024 – click here and here;
- United States: IRS Large Business and International (LB&I) division released practice units: International tax issues including branch profits tax, Hedge fund basics, and Base Erosion Anti-Abuse Tax (BEAT) – click here;
- Australia: the Australian Taxation Office (ATO) publishes the list of consultation matters registered in 2022 that have been completed; Advance pricing arrangements program review and Automatic Exchange of Information guide and toolkit for Reporting Financial Institutions – click here and here;
- Australia: ATO publishes the list of consultation matters registered in 2024 that have been completed; Local File/Master File (LCMSF) Schema Version 4.0 short form local file instructions, Advance pricing arrangement program review recommendations, Inbound related party financing by private groups in the property and construction industry – click here, here and here;
- Australia: ATO publishes the list of matters under consultation; Public country-by-country reporting transparency measure and exemption discretions – click here;
- Australia: ATO publishes list of Advice under development – international issues; Public Country-by-Country reporting transparency measure and exemption discretions and Pillar Two global and domestic minimum tax – click here and here;
- Saudi Arabia: Saudi Arabia enhances transfer pricing certainty with new APA guidelines – click here;
- Qatar: Introduction of Pillar Two global minimum tax rules – click here;
- Japan: 2025 tax reform bills, including Pillar Two rules, passed by Parliament – click here;
- OECD: OECD 2023 APA and Mutual Agreement Procedure (MAP) statistics: Insights from the perspectives of the Chinese Mainland and Hong Kong SAR – click here;
- India: India Achieves Record 174 Advanced Pricing Agreements in 2024/25 Financial Year – click here;
- India: India’s Central Board of Direct Taxes (CBDT) expands transfer pricing safe harbour rules and raises transaction limits for select services – click here;
Romania
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Pros and cons of the minimum turnover tax: The Government collects additional RON 5 billion per year, but 148 companies are already at a loss and 90 profitable companies will become loss-making, according to a study by the Romanian think thank “The Tax Institute” (RO) – click here and here for the press releases and here for the study;
- Romanian interim president, Ilie Bolojan, about the impact of tax evasion on the economy and minimum turnover tax (RO) – click here;
- The Ministry of Finance will be able to officially request advisory views from the Chamber of Tax Consultants for tax projects (RO) – click here for the press release and here for the Government Emergency Ordinance document;
- New trend in NAFA inspections: Temporary tax decisions are issued that, in fact, remain final, says a lawyer specializing in taxation (RO) – click here and here;
- NAFA will publish the “white list” for the first quarter of 2025 this month (RO) – click here;
- Tax obligations calendar for April 2025: What are the tax obligations that taxpayers have this month? (RO) – click here and here;
- Form 107: details the submission deadline in 2025 (RO) – click here;
- The "pole tax" was reduced by half by the government through an emergency ordinance adopted on Thursday; The impact on the private sector will be around RON 300-350 million, 75% of the amount will be paid by state-owned companies (RO) – click here, here and here;
- The government's "pole tax" brings unnecessary stress to the business environment, explains a specialist (RO) – click here;
- Tax on special constructions – “pole tax”: 6 changes announced by the Ministry of Finance (RO) – click here;
- Cornelia Nastase, CEO, CC Tax Advisory: Romania and Uganda have the same number of employees specialized in advance pricing agreements. If NAFA would specialize more people, it would avoid litigation and additional costs (RO) – click here;
- D&B David and Baias Opinion: When can a simple transfer of personnel between companies actually be considered a transfer of enterprise? Implications and sanctions (RO) – click here;
TP Cases
- Italy: Supreme Court rules on “look-through approach” for certain medium and long-term loans; The Court of Justice of the European Union (CJEU) Advocate General’s opinion: Imposition of Italian regional tax on productive activities (IRAP) on dividends may be inconsistent with Parent-Subsidiary Directive (PSD) depending on nature of tax – click here and here;
- The Netherlands: Capital loss upon liquidation of subsidiary allowed (Supreme Court decision) – click here.
