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Europe
- EU: The European Commission publishes implementing regulation to facilitate automatic exchange of tax information under DAC9 – click here;
- United Kingdom: United Kingdom government publishes draft law to tackle tax avoidance schemes – click here;
- France: The French tax authorities (DGFIP) published a new Charter governing advance pricing agreements (APAs) to modernise and strengthen framework – click here;
- Germany: Germany suspends new advance pricing agreements with China – click here;
- Ireland: Updated CRS (Common Reporting Strandard) guidance – click here;
- Moldova: Legislation amending transfer pricing rules – click here;
- Ukraine: Ukraine clarifies transfer pricing penalty changes effective from March 2025 – click here;
- Andorra: European Commission adopts proposal for council decision on amending protocol to automatic exchange of financial account information (AEOI) under the OECD’s common reporting standard (CRS) agreement with Andorra – click here;
Global
- OECD: OECD releases latest transfer pricing profiles for twelve tax jurisdictions (i.e. Austria, Belgium, Canada, Ireland, Latvia, Lithuania, Mexico, the Netherlands, New Zealand, Singapore, South Africa, and Spain) – click here and here;
- OECD: Reports on developments in international tax cooperation and transparency – click here;
- OECD: OECD publishes peer review reports on tax information exchange for Honduras, Madagascar, Mongolia, Oman, Trinidad and Tobago – click here and here;
- EU: CFE’s Tax Top 5 – 22 July 2025 – click here;
- Transfer pricing briefing – Second Quarter of 2025 – click here;
- OECD: Determining the Price of Minerals: A transfer pricing framework for copper – Public consultation, deadline 5 September 2025 – click here;
- Tax treaty round up (July 2025) – click here;
- United States: M&A Tax Talk: Understanding Pillar Two's impact on mergers and acquisitions – click here;
- Taiwan: Clarification of requirement to prepare transfer pricing report or substitute documentation if specified conditions met – click here;
- Chile: Taxation of shares in company resident in preferential tax regime under indirect sale rule; other direct and indirect tax developments – click here for the press release and here for the bilingual report;
- Argentina: Argentina has signed addendum to CRS MCAA - an OECD update – click here;
- Greenland: Greenland has signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) - an OECD update – click here;
Romania
- Legislative changes on advance pricing agreements and procedures for avoiding double taxation: Government Ordinance no. 11 of July 24, 2025, for amending and supplementing Law no. 207/2015 on the Fiscal Procedure Code (RO) – click here for the press release and here for the complete legislative framework;
- The Ministry of Finance issued a press release announcing that the Government had made changes to the Fiscal Procedure Code, whereby advance pricing agreements could, surprisingly, also be applied retroactively for up to five years (RO) – click here;
- The saga of the NAFA notification from SPV (Virtual Private Space): The reaction of accountants after the Tax Office's clarifications. "It has nothing to do with the export of profits". NAFA will not apply sanctions to those who do not respond to the requests (RO) – click here and here;
- The interim leader of PSD (Social Democratic Party), Sorin Grindeanu, announces turnover taxation for all companies with profit tax and taxation of profit export in Romania (RO) – click here;
- Loans between two companies: Tax rules and legal limitations in 2025 (RO) – click here;
- Deputy Prime Minister for Reform, Dragos Anastasiu, about the thousands of companies with the same address: The basic problem is not to commit tax evasion through carousel fraud. NAFA will have to do its job (RO) – click here;
- How does NAFA respond to accusations regarding weak VAT collection (RO) – click here;
- The Government is preparing a second package of fiscal measures that could bring important changes to the Romanian tax system (RO) – click here and here;
- Dividend tax increased to 16% from January 1, 2026. What rate applies to dividends from previous years? (RO) – click here;
- ONPCSB (National Office for the Prevention and Combating of Money Laundering) Notification: Which entities are obliged to submit it within 15 days and what does it look like? (RO) – click here;
TP Cases
- France: France v Axa provides a practical illustration of how the burden of proof is applied in TP matters under French law – click here;
- Belgium: Obligation to pay top-up tax under UTPR (Undertaxed Profits Rule) on low-taxed profits of group members outside Belgium (CJEU referral) – click here;
- Czech Republic: Czech Republic vs Inventec s.r.o., June 2025, Supreme Administrative Court, Case No 22 Afs 3/2025 – 75 (80) – use of appropriate profit level indicator – click here;
- India: Indian tax authority wins PE (permanent establishment) tax case against Hyatt International – click here;
- Kenya: Application of median rate in computing net profit not required (Tax Appeal Tribunal decision) – click here for the press release and here for the tribunal decision;
Webinars
- Romania: List of webinars for August, published on the NAFA portal – click here.
