brought to you by TPS
Europe
- EU: The European Parliament adopted a legislative resolution on the European Commission’s proposal for a Business in Europe: Framework for Income Taxation (BEFIT) Directive – click here;
- Austria: Draft Tax Amendment Act 2025 includes implementation of DAC9, incorporation of OECD Pillar Two administrative guidance – click here;
- Bulgaria: Ministry of Finance (MoF) updates transfer pricing rules and aligns them with the latest OECD guidelines – click here;
- Czech Republic: Draft policy statement of incoming government coalition includes mandatory transfer pricing documentation – click here;
- Italy: Decree issued on Pillar Two domestic filing and payment obligations – click here;
- Montenegro: Montenegro signs the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI) – click here;
- Spain: Three new Pillar Two forms approved: Forms 240, 241, and 242 – click here;
- Switzerland: Application of Pillar Two rules to hybrid arbitrage arrangements under country-by-country (CbC) reporting safe harbor, applicable to transactions entered into after December 18, 2023 – click here for the press release and here for the Federal Tax Administration communication;
- Switzerland: Consultation on protocol amending the automatic exchange of financial account information (AEOI) agreement with EU. The consultation will remain open until February 6, 2026. – click here;
- UK: HM Revenue & Customs (HMRC) transfer pricing settlement policy - Advice issued by HMRC to their compliance teams on settling transfer pricing enquiries. – click here and here;
Global
- OECD: New peer review reports on tax transparency and Exchange of Information for Tax Purposes (EOIR) released (November 2025) – click here;
- United States: Internal Revenue Service (IRS) Insights (November 2025) – click here;
- Hong Kong SAR: Inland Revenue Department (IRD) will issue digital Certificates of Resident Status (CoRs) for claims under China Mainland double taxation arrangement (DTA) – click here and here;
- Taiwan: Reminders related to claw back of retained earnings tax incentive, controlled foreign company rules – click here;
- Singapore: Guidance on foreign-sourced capital gains and interest income – click here;
- Kazakhstan: Amendments to transfer pricing framework, effective January 1st, 2026 – click here;
- Australia: Pillar Two: From policy to practice - Issues for financial services & insurance sectors – click here;
- Australia: Australian Taxation Office (ATO) releases draft instructions in respect of public country-by-country reporting – click here;
- Australia: Country-by-country reporting deadline extended to January 30, 2026 (for reporting periods that ended on December 31, 2024) – click here;
- South Africa: Compliance requirements for income transfers by residents to nonresidents – click here;
Romania
- Transfer pricing file – corresponding corrections following differences established by the tax authority – click here;
- Amendments to Pillar Two rules to align with OECD model rules and EU directive – click here;
- Tax Magazine No. 5 – September – October 2025 – click here;
- NAFA intensifies tax inspections against large taxpayers; Over 500 large taxpayers are targeted – click here and here;
- NAFA supports multinational enterprises through the awareness campaign regarding the R404 Country-by-Country Report (CbCR) for fiscal year 2024 – click here;
- NAFA publication - Legislative news - bulletin no. 41 of November 10, 2025 – click here;
- NAFA will have a chatbot - Ana. "It will be NAFA's surprise in the near future and will actually represent a capitalization in this area of artificial intelligence assistance." – click here;
- NAFA is currently working on interconnecting existing digital systems, such as e-Invoice and SAF-T, to streamline targeted inspection activity, said Magdalena Gradinaru, general director of the Information Management Unit. – click here;
- Deloitte Opinion - Dispute resolution in the area of transfer pricing – practical aspects in Romania and other Central and Eastern European (CEE) countries – click here;
- Dividend tax - 10% or 16%? What rate applies to the profit registered in October-December 2025 – click here;
- Increase in dividend tax rate can still be avoided. Eliminating turnover tax would help investment, says leading economist – click here;
- The Ministry of Economy will propose the elimination of turnover tax – click here;
- Microenterprise tax - "I think it's a very good idea to have a single rate. It's under our consideration," says the Minister of Finance – click here and here;
TP Cases
- The Netherlands: the Court of Appeal of Amsterdam rules that the outcome of a Mutual Agreement Procedure (MAP) does not have retroactive effect, similar to the Court of Appeal of The Hague ruling – click here for the press release and here for the full text of the judgment.
