brought to you by TPS
Europe
- United Kingdom: Updates to new guidance manual on Pillar Two – click here;
- Slovakia: Bill implementing DAC8 approved by Parliament; consultation on implementation of DAC9 – click here;
- Switzerland: Updated list of jurisdictions for exchange of country-by-country reports – click here;
Global
- OECD: 2025 Global transfer pricing updates - OECD Amount B and important country updates – click here;
- OECD: OECD publishes updated signatory list for the Multilateral Competent Authority Agreement on the Exchange of GloBE Information Return (GIR MCAA) – click here;
- AI future in tax integrates human expertise and machine learning – click here;
- Australia: Consultation on draft legislation providing exemptions from obligation to file Pillar Two tax returns – click here;
- Costa Rica: Transfer pricing informative return requirement introduced – click here;
- Peru: Peru to implement BEPS multilateral instrument – click here;
- Mexico: Transfer pricing compliance options for maquiladoras (a maquiladora is a factory that is largely duty free and tariff free) regarding advance pricing agreement (APA) program transition – click here;
- Vietnam: Guidance on implementation of Pillar Two rules – click here;
- Uruguay: Budget proposals include Pillar Two minimum tax – click here;
Romania
- The Government keeps the minimum turnover tax. A new mechanism limiting deductibility will also be introduced, but only for multinationals with a turnover below EUR 50 million (RO) – click here and here;
- The new president of NAFA will be interrogated by a committee of the Parliament (RO) – click here;
- Form D700 NAFA. Deadline + conditions for companies that want to revert to the calendar fiscal year (RO) – click here;
- Prime Minister of Romania: The tax reform project corrects many shortcomings. The measures will bring to light the ghost companies / We have over 460,000 inactive companies and a third have debts to the state of over RON 3.5 billion (RO) – click here;
- The new cases in which companies can be declared inactive: The most important changes for entrepreneurs (RO) – click here;
- The final text of the law regarding companies: The minimum turnover tax (IMCA) remains valid, as well as the tax on transactions engaged with affiliated parties. The tax rate for large fortunes increases, new changes regarding share capital for limited liability companies (SRLs) are introduced, and others (RO) – click here;
Webinars
- New Danish transfer pricing documentation rules (23 Sep. 2025) – click here;
- Transfer pricing in Europe and the USA (23 September, 10 AM EDT) – click here;
TP Cases
- Zambia: Supreme Court rules in ZRA v. Nestlé transfer pricing case – click here;
- Eighth Circuit: Tax Court’s application of unspecified transfer pricing method rejected – click here;
- EU: Intra-group payments under the transactional net margin method subject to VAT (CJEU judgment) – click here.
