brought to you by TPS
Europe
- United Kingdom: HM Revenue & Customs (HMRC) publishes 2025 edition of annual corporation tax statistics – click here;
- Germany: Draft amendments to Pillar Two rules adopted by Federal Cabinet; draft bill to implement DAC8; other tax developments – click here;
- Switzerland: Global Anti-Base Erosion (GloBE) reporting regulations adopted by Federal Council – click here;
- Greece: List of noncooperative jurisdictions for FY 2024 issued – click here;
- Denmark: Updated DAC7 reporting guidance – click here;
- Sweden: Proposed changes to targeted interest deduction limitation rules – click here;
Global
- OCDE & Argentina: Argentina submits instrument of ratification for BEPS Convention – click here;
- Australia: Final Australian Taxation Office (ATO) guidance on third party debt test and related restructures released – click here;
- Kuwait: Electronic registration service for companies subject to domestic minimum top-up tax (DMTT) launched – click here;
- Peru: Multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting (BEPS MLI) enters into force – click here;
- Indonesia: Income tax withholding obligations for e-commerce platforms and online marketplaces – click here;
- Saudi Arabia: Mandatory e-invoicing for taxpayers with revenue above SAR 375,000 – click here;
- United Arab Emirates: Framework, scope, and implementation of e-invoicing system – click here;
Romania
- The legislative history of a controversial package – an overview of some of the radical measures adopted to overcome the budgetary-fiscal crisis – click here;
- Lessons from the NAFA “Ghost Nest” Operation: what should be done and avoided concerning “tax domicile” – click here;
- NAFA Calendar - tax declarations to be submitted in October 2025 – click here;
- The Government has approved the budget amendment. The deficit target for this year increases to 8.4% of GDP – click here;
- The Tax Council - the deficit should be around 6.5% for 2026. Without adjustment measures, this year's deficit would have reached 9%, versus 8.67% last year – click here;
- How the pressure of tax compliance can become an advantage for companies – click here;
- e-Invoicing. Notification 800 introduced for those who do not receive invoices through the system – click here;
TP Cases
- Romania: Final court ruling clarifies intra-group services: Marketing & R&D costs are deductible; Tax Authorities cannot apply an “opportunity/business need” test and must assess necessity holistically – click here or here;
- Romania: Decision of the High Court of Cassation and Justice – a landmark tax victory regarding international intra-group expenses and packaging waste recycling – click here;
- Belgium: Transfer pricing dispute concerning royalties, factoring fees, and interest deductions – click here;
- Spain: Arm’s length remuneration in cash pooling arrangements of multinational groups – click here;
- United States: Eighth Circuit - reallocation of blocked royalty income not allowed under section 482 – click here;
- United States & Korea: Royalties from patents not registered in Korea may be subject to tax in Korea under U.S. treaty; other tax developments – click here.
