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Europe
- Germany: Press release from 3 German States (Bavaria, Hesse, and North Rhine-Westphalia) announcing they will request Federal parliament to suspend global anti-base erosion model (GloBE) rules, pending resolution of treatment of US multinationals – click here or here;
- Germany: The German Ministry of Finance (MOF) consults filing rules for global anti-base erosion model (GloBE) Information Return – click here;
- Belgium: Country’s arbitration position under Part VI of base erosion and profit shifting multilateral instrument (BEPS MLI) – click here;
- Bulgaria: Bulgaria consults proposed transfer pricing reforms, positions to match OECD standards – click here;
- Lithuania: Tax authority revises guidance to clarify corporate tax rates – click here;
- Greece: Update indicates that Greece has signed Multilateral Competent Authority Agreement on Automatic Exchange of Information on Income Derived Through Digital Platforms (DPI MCAA) – click here;
- Denmark: Denmark updates platform reporting rules under DAC7, DAC8 – click here;
- Denmark: Denmark expands Country-by-Country (CbC) reporting requirements – click here;
- Sweden: The Sweden Ministry of Finance (MoF) proposes amending targeted interest deduction limitation rules – click here;
- Finland & Liechtenstein & Norway: Update indicates that Finland, Liechtenstein, and Norway have signed Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) – click here;
- France: Guidance on global anti-base erosion model (GloBE) rules – click here;
- Netherlands: Country’s arbitration position under Part VI of base erosion and profit shifting multilateral instrument (BEPS MLI) – click here;
- Netherlands & Italy: Top 5 mutual agreement procedure (MAP) partners of the Netherlands: Italy – click here;
- United Kingdom: UK tax authority (HMRC) launches “one-to-many” letter campaign in respect of management expenses – click here;
- United Kingdom: Head office costs – transfer pricing and deductibility – click here;
Global
- OECD: TP issues regarding special purpose vehicles (SPV) investments – click here;
- India: Enhancing certainty, transparency and uniformity in permanent establishment and profit attribution for foreign investors in India – click here;
- India: Application of principal purpose test in multilateral instrument (MLI) requires separate notification under India-Ireland treaty – click here;
- United States: Notice 2025-49 – provides additional interim guidance on corporate alternative minimum tax (CAMT) – click here;
- United States: Notice 2025-46 – provides interim guidance on corporate alternative minimum tax (CAMT) – click here;
- United States: Internal Revenue Service (IRS) extends treaty benefits to reverse foreign hybrids subject to branch profits tax – click here;
- United States: A full carve-out for US groups for Pillar 2: an European Union Constitutional Trojan Horse? – click here;
- United States: Comparable transaction risk analysis: Internal Revenue Service (IRS) guidance – click here;
- Hong Kong: Updated guidance on global anti-base erosion model (GloBE) rules – click here;
- Hong Kong: The Hong Kong Inland Revenue Department (IRD) extends filing deadline for 2024-2025 profits tax returns – click here;
- Global: Current list of signatories to Multilateral Competent Authority Agreement on Exchange of GloBE Information (GIR-MCAA) – click here;
- Global: The shifting landscape of intercompany services: a transfer pricing review – click here;
- Global: 2026 update to OECD Transfer Pricing Guidelines – topics likely to be covered – click here;
- Global: Profit splits in Transfer Pricing: what is the nature of adjusting payments? – click here;
- Israel: Israel releases legislation for 15% global minimum tax – click here;
- Israel: Draft Pillar Two legislation – click here;
- Brazil: Amendments to domestic minimum top-up tax – click here;
- Brazil: Brazil updates Contribution on Net Profit rules, aligns with qualified domestic minimum top-up tax (QDMTT) under Pillar 2 – click here;
- Brazil & United States: Brazil, United States sign agreement on automatic tax data sharing – click here;
- Ecuador & Romania: Ecuador, Romania sign Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (CRS MCAA) addendum – click here;
- South Africa: Update indicates that South Africa has signed Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) – click here;
- New Zealand: Red light, green light – Transfer pricing issues for intercompany loans – click here;
- New Zealand: What is actually happening with Country-by-Country (CbC) reports? – click here;
- New Zealand: Country’s arbitration position under Part VI of base erosion and profit shifting multilateral instrument (BEPS MLI) – click here;
- Turkey: Turkey consults Pillar 2 global minimum tax implementation – click here;
- Uruguay: Economy and Finance Minister proposes amendments to global minimum tax for 2025–2029 budget bill – click here;
- Kazakhstan: The Kazahstan Ministry of Finance (MoF) approves new Controlled Foreign Companies (CFC) reporting, taxation forms for 2026 – click here;
- Australia: Country’s arbitration position under Part VI of base erosion and profit shifting multilateral instrument (BEPS MLI) – click here;
Romania
- Romania joins crypto-asset reporting framework (CARF-MCAA) – click here;
- The President of the Chamber of Tax Advisors (Dan Manolescu) - I don’t believe we will reach the end of the year without new tax changes. Starting next year, the excise duty on sugar could be extended, while the surtax on oil and gas companies might be prolonged. – click here;
- The Romanian Tax Authority (NAFA) and the Tax Authority of the Republic of Moldova will cooperate to improve processes and institutional capacities. – click here;
- Ilie Bolojan (The Romanian Prime Minister) - The turnover tax needs to be reconsidered. – click here;
- Form for declaration and payment of Pillar Two taxes approved – click here;
- Changes to the tax payment rescheduling system: what is changing, who can still benefit, how, and most importantly, at what cost? – click here;
- RO e-Invoice 2025: The Romanian Tax Authority (NAFA) explains which notification companies must send when they do not receive an electronic invoice following a business to business (B2B) purchase. Form 800. – click here;
TP Cases
- United States: 3M case (Transfer pricing “blocked income” case; application of Loper Bright) – click here.
