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Europe
- Moldova: Annual submission of transfer pricing file no longer required – click here;
- The Netherlands: Ministry of Finance publishes tax plan for 2026, including Pillar Two changes and implementation of DAC9 – click here and here;
- Switzerland: The Federal Council adopted a dispatch regarding the exchange of information in the area of OECD minimum taxation – click here;
- Poland: Consultations on Pillar Two forms and anti-avoidance regulations; other tax developments – click here;
- Russia: The Federal Tax Service (FTS) consults on revising jurisdiction list for country-by-country (CbC) report exchange – click here;
- Hungary: Update indicates that Hungary has signed addendum to Common Reporting Standard Multilateral Competent Authority Agreement (CRS MCAA) – click here;
- Ukraine: Constituent entities of multinational enterprise (MNE) groups parented in U.S., Canada, or Israel must file 2024 country-by-country (CbC) reports locally – click here;
- Ukraine: Ukraine sets deadline for 2024 transfer pricing report (i.e. 30 September 2025), notification – click here;
- Czech Republic: Amendments to Pillar Two rules signed by president – click here for the press release and here for the Czech Parliament Act;
- Slovakia: Guidance on financial transaction tax – click here;
- Portugal: Pillar Two notification form and instructions – click here;
- Finland: Ministry of Finance consults DAC9 reporting rules – click here;
- Finland: Parliament reviews bill to enforce DAC8 crypto reporting – click here;
- Norway & US: Norway-US tax treaty: Withholding tax and US regulated investment companies (RICs): A new era of treaty protection – click here;
- Malta: Regulations on 15% “elective tax” published – click here;
- Isle of Man: Pillar Two registration now available via tax authorities’ online services – click here;
- Jersey & Isle of Man: Pillar Two transitional qualified status achieved – click here;
- Georgia: Georgia expands Base Erosion and Profit Shifting Project Multilateral Instrument (BEPS MLI) coverage with 22 new tax treaties – click here;
- France: Fitch downgraded France's sovereign credit rating to its lowest level ever, from AA- (high quality) to "A+" (upper average quality), in the context of the ongoing political crisis and rising debt – click here;
Global
- OECD: Updated list of signatories to the Multilateral Competent Authority Agreement on the Exchange of global anti-base erosion (GloBE) Information (GIR MCAA) – click here;
- OECD: Revised Base Erosion and Profit Shifting Project (BEPS) action 5 transparency framework regarding tax rulings released – click here for the press release and here;
- OECD: 2025 report on tax policy reforms released – click here for the press release and here for the OECD publication;
- United States: Application of income tax treaties to branch profits tax of certain hybrid entities – click here;
- United States & Dominican Republic: United States - Dominican Republic country-by-country (CbC) reporting exchange agreement enters into force – click here;
- Paraguay: Law updates the maquiladora (i.e., a factory that is largely duty free and tariff free) regime – click here;
- Bermuda: Consultation paper on proposed tax credits published – recommendations on the OECD substance-based income exclusion provisions in the global anti-base erosion (GloBE) or “Pillar Two” model rules – click here;
- Hong Kong & Jordan: Hong Kong SAR-Jordan comprehensive double taxation agreement (CDTA) signed – click here;
- Mauritius: Assessment Review Committee upholds arm's length principle for domestic interest-free loans – click here;
- Cayman Islands: Country-by-country reporting and registration functions relaunched on Department for International Tax Cooperation (DITC) portal – click here;
- Sri Lanka: Sri Lanka joins global forum on tax transparency – click here;
- Kazakhstan: Changes to definitions (e.g. royalty, interest, dividends, related parties), legal principles under new Tax Code – click here;
Romania
- NAFA initiated tax inspections with 120 anti-fraud inspectors in three commercial and logistics complexes in Bucharest and Ilfov County. 1,100 storage spaces were closed (RO) – click here and here;
- Moody's rating agency confirmed Romania's country rating at "Baa3". "Significant risks remain". Alexandru Nazare, Minister of Finance - We must lay the foundations for healthy economic growth in Romania (RO) – click here and here;
- Over 75% of companies' arrears to NAFA are not recoverable. A third of the debts belong to state-owned companies (RO) – click here;
- Alexandru Nazare, Minister of Finance - The years 2025-2026 will be difficult, but 2027 could be a year of fiscal relaxation (RO) – click here;
- Adrian Nicusor, NAFA President - NAFA exceeded the collection plan by RON 1 billion in July. Opinion about databases and the digitalization process (RO) – click here;
- In the first 8 months of 2025, NAFA imposed additional payment obligations of RON 2.5 billion on companies following tax inspections (RO) – click here;
- NAFA President explains, in a Parliament hearing, the reason for frequent inspections on small taxpayers (RO) – click here;
TP Cases
- Germany: Legislation incorporating authorized OECD approach to permanent establishments (PEs) not an independent rule for determining PE profit (Federal Fiscal Court decision) – click here;
- Belgium: Court of First Instance of Brussels favors legalistic interpretation of beneficial ownership in EU interest and royalties directive (IRD) implementation – click here for the press release and here for the judgement of the Court;
- Latvia: Court of Justice of the European Union (CJEU) referral on interpretation of tax dispute resolution mechanisms directive – click here;
Webinars
- TPA Global Webinar - How to Optimize Your Global Transfer Pricing Documentation Cycle for FY25, Wednesday, 1st October 2025, 16:00 – 17:00 CET - click here for the details and here for the registration form;
- KPMG Digital Nomad webinar, in collaboration with the Embassy of Japan in Romania – among others, elimination of double taxation under the tax treaty between Japan and Romania, 25th September – click here.
