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Europe
- Germany: Germany mandates transaction matrix transfer pricing documentation requirement – click here;
- Germany: Ministry of Finance clarifies application of Country-by-Country (CbC) reporting for transparent partnerships – click here;
- Switzerland: Switzerland revises jurisdictions for Country-by-Country (CbC) report exchange – click here;
- Cayman Islands: Cayman Islands updates Common Reporting Standard (CRS) jurisdiction lists – click here;
- United Kingdom: United Kingdom consults advance tax clearance service for large innovative investment projects, transfer pricing treatment of Cost Contribution Arrangements (CCAs) – click here;
- Norway: Norway will not implement Amount B but will accept it from other jurisdictions – click here;
- Luxembourg: Luxembourg adopts draft legislation approving tax treaty with Colombia – click here;
- Turkey: Turkiye confirms Amount B of OECD Pillar One will not apply to local intermediary transactions – click here;
- EU: BusinessEurope warns European Union that Pillar Two could harm competitiveness amid shifting global tax landscape – click here;
Global
- OECD: OECD adds Guernsey to list of qualified Pillar Two jurisdictions – click here;
- United States: Advance Pricing Agreements (APAs) report for 2024 highlights sustained efficiency with high volume of executed APAs – click here;
- United States: Does transfer pricing have a Loper Bright problem? – click here;
- India: Central Board of Direct Taxes (CBDT) signs record number of advance pricing agreements in FY 2024 – FY2025 – click here;
- Uruguay: Uruguay presents bill proposal to approve double taxation treaty with Turkiye – click here;
- New Zealand: New tax governance guidance – click here;
Romania
- The erroneous practice of the tax authorities of using the National Bank of Romania's reference interest rate, regulated by Government Ordinance no. 13/2011 on the remunerative and penalty legal interest for monetary obligations and the regulation of certain financial-fiscal measures in the banking sector, as the market price level for the interest rate applied in transactions between affiliated persons (RO) – click here;
- NAFA inspectors breach the Fiscal Code by erroneously considering that the National Bank of Romania's key interest rate is an arm's length rate for intra-group loans, say tax consultants (RO) – click here and here;
- What situation can companies face during an unexpected inspection by NAFA’s Anti-Fraud division / What recently happened to a company with foreign shareholders? (RO) – click here;
- Accelerating the settlement of amicable procedures, a priority for improving the tax system in the context of OECD accession efforts (RO) – click here;
- Companies will face major changes in tax and trade policies globally (RO) – click here;
- Pole tax. 5 important changes, implemented from 2025 (RO) – click here;
TP Cases
- Lithuania: Application of participation exemption, abuse provision (CJEU judgment) – click here;
- European Union: Transfer pricing adjustments are subject to VAT (CJEU Advocate General opinion) – click here.
