Europe

  • EU: EU Commission withdraws proposed transfer pricing directive – click here;
  • EU: The European Tax Adviser Federation (ETAF): Position paper on need to strengthen professional secrecy for tax advice in EU – click here;
  • Europe: OECD report: Navigating transfer pricing audits in Central Europe: trends, risks, and practical insights – click here;
  • EU: Summit of EU Tax Administrations took place in Copenhagen – click here;
  • Hungary: Update indicates that Hungary has signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) – click here;
  • Italy: Global anti-base erosion (GloBE) information return (GIR) and filing instructions – click here;
  • Guernsey: Initial Pillar Two guidance – click here;
  • Malta: Malta launches 15% final corporate tax regime as a simplified alternative to imputation system – click here;
  • Luxembourg: Transfer Pricing Forum: How tariffs impact supply chain strategies and transfer pricing models in Luxembourg (Loyens & Loeff) – click here and here;
  • Netherlands: Challenge to EU minimum tax directive on standing grounds (Court of Justice of the European Union judgment) – click here;

Global

  • Australia: Weekly tax round-up (3 November 2025) – click here;
  • Australia: The Australian Taxation Office (ATO) releases updated guidance on the Advance Pricing Arrangement program – click here and here;
  • Australia: Consultation open: draft Public country-by-country (CBC) lodgment instructions – click here and here;
  • Australia: Redesigned Voluntary Tax Transparency Code (VTTC) – click here;
  • South Africa: The South African Revenue Service (SARS) extends due dates for certain Pillar Two notifications and returns – click here;
  • Indonesia: The challenges of software distribution payments: A tax perspective – click here;
  • Mauritius: Qualified domestic minimum top-up tax (QDMTT) notification platform open, deadline for notifications extended to November 30 – click here;
  • Canada: Direct and indirect tax measures in 2025 federal budget, including amendments to modernize transfer pricing rules – click here;
  • Costa Rica: Costa Rica’s tax administration (DGT) updates transfer pricing return dates for fiscal years 2024 and 2025 – click here;
  • Kenya: The Kenya Revenue Authority (KRA) consults on draft income tax regulations for advance pricing agreement, minimum top-up tax for 2025 – click here;
  • Brazil: Transfer pricing implications of proposed 10% dividend withholding tax for multinational entities (MNEs) – click here;
  • Japan: Guidance on amendments to income inclusion rule (IIR) and controlled foreign company (CFC) regime under 2025 tax reform – click here;
  • Israel: Final guidance regarding local research and development (R&D) centers and intellectual property (IP) valuations – click here;
  • Singapore: Classification of foreign entities for Singapore income tax purposes – click here;
  • Kenya: The draft Income Tax (Advance Pricing Agreement) Regulations, 2025 and the draft Income Tax (Minimum Top Up Tax) Regulations, 2025 – click here;
  • Macau: Transfer pricing regulations (Government) – click here;

Romania

  • NAFA inspectors will be monitored by a new internal structure – click here;
  • How NAFA determines large and medium-sized taxpayers - Criteria and inclusion rules – click here;
  • 11 – 12 November 2025: The Taxation and Technology Summit brings together industry leaders at Romexpo: the Minister of Finance and the president of NAFA will be on the stage – click here and here;
  • Romania ratifies new tax treaty with the United Kingdom – click here;
  • New tax registration procedure for persons or entities, subject to tax, who have not complied with their registration obligations – click here;

TP Cases

  • EU: Transfer pricing adjustments and their effects on VAT — new case law, risks and suggestions – click here;

Webinars

  • India: 20 November 2025, Dbriefs Asia Pacific Webcast: Hyatt ruling addresses permanent establishment (PE) implications and profit attribution – click here and here;
  • EU: 26 November 2025, KPMG: EU tax perspectives – click here;
  • Global: 20 November 2025, LCN: An introduction to transfer pricing for legal and intellectual property (IP) professionals – click here.

 

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Note: Please note that TPS could not be held responsible for the content and accuracy of the information obtained by accessing these websites, nor for the consequences resulted from any activities one performs based on this information. Even though we are monitoring the outbound links, we do not have control over the availability of the information offered by external references or how often the information is updated.

Contacts

email: letstalk@transferpricing.global 

phone: 0040 742 159 142

 

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