brought to you by TPS
Europe
- EU: Updates on tax initiatives in the European Commission 2026 Work Programme - click here;
- France: Tax measures in 2026 Finance Bill include amendments to Pillar Two rules – click here;
- Hungary: Tax declaration Form 24GLBADO for qualifying domestic minimum top-up tax – click here;
- Czech Republic: Recent amendments to Top-up Taxes Act include extensions of filing deadlines – click here;
- The Netherlands: Guidance on scope of Anti-Tax Avoidance Directive (ATAD) interest deduction limitation rules - click here;
- The Netherlands: Ministry of Finance consults on tax measures for cross-border transactions – click here and here;
- Belgium: Belgium publishes detailed guidance on Pillar 2 Global Minimum Tax – click here;
- Germany & Switzerland & The Netherlands: German Federal Council Approves Pending Protocols to Tax Treaties with the Netherlands and Switzerland – click here;
- Poland: Parliament approves increased corporate taxes on financial institutions – click here;
- Guernsey: Tax authority issues first in new series of Pillar Two guidance – click here;
- UK: Transfer pricing: can HMRC raise more corporate tax from "high-value" intragroup services? – click here;
Global
- OECD: OECD published updates for 25 transfer pricing country profiles, and published new profiles for Cabo Verde, Guatemala, Thailand, United Arab Emirates, and Zambia – click here;
- OECD: Countries Still Split on Minimum Tax Talks, OECD Chair Says – click here;
- OECD: OECD Pillar Two compliance costs: A quantitative assessment for EU - headquartered groups – click here;
- Australia: Guidance on transitional Country-by-Country (CbC) reporting safe harbor under Pillar Two rules – click here;
- Australia & Ukraine: Tax treaty between Australia and Ukraine signed – click here;
- Brazil: OECD - Brazil signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) – click here;
- Brazil: Brazilian National Congress confirms provisional measures increasing taxation of interest on net equity and financial institutions is no longer valid – click here;
- Colombia: Colombian tax authority amends reporting obligations for digital platform operators under the OECD multilateral agreement – click here;
- Philippines: E-invoicing compliance deadline extended to December 31, 2026 – click here;
- India: India proposes to transform permanent establishment and profit attribution rules – click here;
- Kazakhstan: Kazakhstan 2026 tax code: A full reset of the country’s approach to corporate taxation – click here;
- Vietnam: Ministry of Finance introduces procedures and forms for Pillar 2 minimum tax compliance – click here;
Romania
- Companies in Romania might escape from filling tax declarations by using the SAF-T reporting system – click here;
- The Constitutional Court of Romania (CCR) signals constitutional issues in two fiscal laws: package three coming next, with new restrictions and a potential minimum tax review – click here;
- NAFA leadership will have bonuses or penalties tied to performance indicators. Tax authorities have been mandated to calculate the VAT gap biannually. The restructuring will centralize functions at headquarters – click here;
- Merger by absorption - How the process unfolds step by step, according to law no. 31/1990 and OMFP 897/2015 – click here;
TP Cases
- Romania: High Court of Cassation and Justice (HCCJ): decision to suspend tax inspection is a general administrative act, not a fiscal administrative act – ruling issued in resolving a jurisdictional dispute – click here;
- Belgium: Interest rate on intra-group loan held non-arm’s length under comparable uncontrolled price method (court decision) – click here;
- Australia: Australia vs Oracle Corporation Australia Pty Ltd, October 2025, Full Federal Court, Case No [2025] FCAFC 145 – click here;
Webinars
- Global: How US Tariffs Are Reshaping Global Transfer Pricing And Customs Strategies – Part 2, 12 November 2025 – click here.
