brought to you by TPS
Europe
- EU: CFE’s Tax Top 5 – 12 May 2025 – click here;
- Belarus: Belarus updates guidance on taxation of foreign organizations operating through a Permanent Establishment – click here;
- Italy: Italy updates reportable and participating jurisdictions under the Common Reporting Standard (CRS) – click here;
- The Netherlands: Position of the Dutch tax authorities on the application of the withholding exemption of the Dutch dividend withholding tax Act in cases the dividend is not eligible for treaty benefits – click here;
- Sweden: Commission refers Sweden to Court of Justice of the European Union (CJEU) for tax deduction on payments to foreign companies – click here;
- UK: Unilateral advanced pricing agreements (APAs) may now be used to solve Cost Sharing Arrangements disputes – click here;
Global
- OECD: OECD updates commentary on global anti-base erosion rules – click here and here;
- Argentina: Senate approves the Multilateral Instrument (MLI) to prevent base erosion and profit shifting (BEPS) – click here;
- Colombia: Colombia’s foreign exchange tax rules for multinational enterprises are difficult – click here;
- Kenya: Tax proposals in Finance Bill 2025, including introduction of advanced pricing agreements (APAs) – click here;
- United States: Internal Revenue Service (IRS) reissues interim guidance on Advance Pricing Agreement submissions – click here and here;
Romania
- NAFA admits: the National Bank of Romania's reference interest rate cannot be used as a benchmark in controls on intra-group loans (RO) – click here;
- The National Agency for Fiscal Administration has launched a public debate on the draft order amending Order No. 3077/2017 of the President of the National Agency for Fiscal Administration approving the standard form "Report on finding and sanctioning contraventions" (RO) – click here;
- Draft Order: NAFA proposes amendments to Forms D100 and D710 in connection with the construction tax implementation (RO) – click here;
- NAFA used the e-Invoice system and went to check a construction company in Bucharest (RO) – click here;
TP Cases
- Korea: Right to claim refund of wrongly withheld tax (Supreme Court decision); VAT monthly reporting; obligation to file Country-by-Country (CbC) report; other tax developments – click here;
- Australia: Alcoa of Australia Ltd v Commissioner of Taxation: A Landmark Transfer Pricing Case – click here;
- Italy: Year-end transfer pricing adjustments under new accounting standard – click here.
