brought to you by TPS
Europe
- EU: DAC9 published in the official journal of the EU – click here;
- Ukraine: Input on experience with application of Ukraine's transfer pricing legislation – click here;
- United Kingdom: UK opens consultations on transfer pricing, permanent establishment, and Diverted Profits Tax legislative reform – click here;
- France: Revised list of non-cooperative jurisdictions issued – click here;
- Switzerland: Public consultation on global anti-base erosion (GloBE) information return – click here;
- Poland: Council of Ministers approve bill to ease group taxation, transfer pricing rules – click here;
Global
- OECD: Transfer pricing country profiles released for 13 jurisdictions, with new sections – click here and here;
- OECD: Summary released of common errors made by multinational enterprise groups preparing country-by-country (CbC) reports – click here;
- Tax treaty round up (May 2025) – click here;
- Australia: Weekly tax round-up (19 May 2025) – click here;
- Australia: The Australian Taxation Office (ATO) updates guidance on Global and Domestic Minimum Tax including new guidance on Pillar Two Interactions with other provisions – click here and here;
- Australia: The Australian Taxation Office (ATO) publishes updated synthesized texts of tax treaties with Denmark and India as impacted by the Base Erosion and Profit Shifting Multilateral Instrument (BEPS MLI) – click here;
- Hong Kong: Inland Revenue Department provides illustrative examples to clarify operation of patent box regime – click here;
- Cambodia: Clarification provided on supporting documents for related party loan interest – click here;
- Bahrain: New guide on Pillar Two minimum tax rules – click here;
- Iran: Iranian Guardian Council approves pending tax treaty with Finland – click here;
- Bermuda: Bermuda corporate income tax administrative regulations published – click here;
Romania
- New provisions regarding the criteria for tax risk assessment – draft project (RO) – click here;
- Synergy or risk? A practical analysis of using group benchmarking studies in local transfer pricing documentation (RO) – click here;
- Granting a loan to the company by the administrator: What are the tax implications? (RO) – click here;
- Form 101 Declaration in 2025. A useful completion guide for companies (RO) – click here;
- PwC Annual Tax Conference. What happens to the data reported through SAF-T, e-Invoice or e-Transport? How can companies ensure accuracy and mitigate potential risks during NAFA audits? (RO) – click here;
- Ultimate Beneficial Owner Declaration. Risk of fines up to RON 10,000 or company dissolution for non-submission (RO) – click here;
TP Cases
- India: Karnataka High Court clarifies scope of “intermediary” for goods and services tax purposes – click here;
- Luxembourg: Interest-free loans treated as equity contributions, branch did not qualify as permanent establishment under Malaysia treaty (High Administrative Court decision) – click here;
- Belgium: Mandatory disclosure rules (DAC6) upheld (Constitutional Court decision) – click here;
- Czech Republic: Czech Republic vs Inventec s.r.o., May 2025, Supreme Administrative Court, Case No 1 Afs 2/2025 – 59 – click here;
- Denmark: Denmark vs EET Group A/S, May 2025, Supreme Court, Case No BS-35371/2024-HJR – click here.
