brought to you by TPS
Europe
- United Kingdom: His Majesty’s Revenue and Customs (HMRC) publishes internal guidance on multinational, domestic top-up taxes – click here;
- Switzerland: Switzerland clarifies top-up tax treatment of residual tax on distributions – click here;
- Italy: Italy implements emergency tax revisions on Controlled Foreign Company (CFC), hybrid mismatch penalty rules – click here;
- Belgium: Impact of new capital gains tax on financial assets on share-based remuneration – click here;
- France: Ruling clarifies withholding tax rules for certain nonresident dividend distributions – click here;
- Luxembourg: Government proposes bill to enforce DAC9, align Pillar Two with OECD standards – click here;
Global
- OECD: List of signatories of the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) – click here or here;
- United Arab Emirates: Federal Tax Authority issues updated guide on private tax clarifications – click here;
- Republic of Korea: Qualified Domestic Minimum Top-up Tax (QDMTT) to be introduced as from 2026 – click here;
- Republic of Korea: 2025 tax revision bill announced – click here;
- Brazil: New updates to e-invoicing layouts – click here;
Romania
- The National Agency for Fiscal Administration appeals to all taxpayers, companies and authorized individuals, in order to ensure correct and complete tax compliance with regard to the declaration and payment of tax obligations (RO) – click here;
- The additional tax. How it is calculated, who is required to declare it and practical case study (RO) – click here;
- Despite all tax reforms, the budget deficit will exceed 8% of Gross Domestic Product (GDP) this year, 3 economists say in a report (RO) – click here;
- Dividend tax. The 16% rate will not apply in 2025 (RO) – click here;
TP Cases
- Luxembourg: Luxembourg court considers economic substance in interest-free loans decision – click here;
- Germany: Services provided by parent company to subsidiaries not “single supply” for VAT valuation purposes – click here;
- Poland: Branch may deduct interest on loan from foreign parent; VAT exemption for private imports – click here;
Webinars
- Transfer Pricing Pulse: Controversy trends shaping the Energy and Natural Resources (ENR) sector in Asia Pacific (APAC), Part 1, Tuesday, 19 August 2025 – click here.
