brought to you by TPS
Europe
- Malta: Provisions concerning mutual assistance in recovery of tax and duty claims introduced – click here;
- Lithuania: Amendments to corporate income taxation effective January 1, 2026 – click here;
- France: No implementation of Pillar One Amount B, but acceptance of Amount B outcomes in covered jurisdictions – click here;
- Slovakia: Slovak Republic updates transfer pricing documentation guidelines – click here;
- Spain: Ministry of Finance issues new Pillar Two global minimum tax forms – click here;
- Germany: Draft legislation to expand the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) to 62 additional treaties; other tax developments – click here;
- UK: Updated list of Pillar Two territories, qualifying top-up taxes – click here;
Global
- OECD: Tax news & views international weekly: The OECD’s 10-year-old tax initiative – click here;
- OECD & Amsterdam: KPMG report: “Amsterdam dialogue on global minimum tax compliance” stakeholder meeting, October 2025 – click here;
- Asia: Asia transfer pricing brief: Q3 2025 – click here;
- Australia: Weekly tax round-up (27 October 2025) – click here;
- Australia: The Australian Taxation Office (ATO) updates advance pricing arrangement (APA) guidance – click here;
- Australia: Pillar Two: The Australian Taxation Office (ATO) releases guidance on transitional Country-by-Country (CbC) reporting safe harbor – click here;
- Argentina: Argentina tightens reporting rules on cross-border transaction – click here;
- South Africa: Updates to global anti-base erosion (GloBE) reporting – click here;
- Global: Debt pricing studies and automation: benefits and risks – click here;
Romania
- NAFA publishes the updated version of the Mutual Agreement Procedure Guide (October 2025)– click here;
- NAFA - Transfer pricing guide updated in October 2025 – click here;
- NAFA inspectors receive great powers - tax inspections at national level, starting with January 1, 2026 – click here;
- NAFA calendar for November 2025 - Deadlines and tax obligations for companies and other taxpayers – click here;
- SAF-T 2025 - Brief NAFA information for companies, regarding the deadline and fines. What is not sanctioned – click here;
- Pillar Two - IFRS becomes optional, deferred tax becomes mandatory – click here;
TP Cases
- Belgium: Ruling affirms preference for use of internal comparable uncontrolled price method to price intercompany loans (court decision) – click here;
- Germany: Federal Tax Court (BFH): Can tax authorities demand the disclosure of emails? – click here;
- Denmark: Holding A/S case – share transactions – non-recognition and recharacterization – click here;
- EU: Fugro’s case: European Court of Justice dismisses Fugro’s appeal seeking partial annulment of EU global anti-base erosion (GloBE) Directive – click here;
- India: Vodafone Idea case – transfer pricing – CUP method – licensing of brand names – royalties – click here;
- Australia: Taxpayer granted stay of domestic tax proceedings pending outcome of mutual agreement procedure (MAP) (Full Federal Court decision) – click here;
- Israel: Value of intangible property need not include “tax gross-up,” but must include “holdbacks” (District Court decision) – click here;
Webinars
- Romania: NAFA online seminars in November 2025 - Microenterprise income tax, payment instalments and other tax topics – click here and here.
