brought to you by TPS
Europe
- European Union: Commission publishes second evaluation of administrative cooperation directives – click here;
- European Union: Report on evaluation of directive on administrative cooperation (DAC) – click here;
- United Kingdom: Treatment of equity accounted affiliates in Global Anti-Base Erosion (GloBE) rules – click here;
- United Kingdom: Transfer pricing – interquartile range – click here;
- United Kingdom: Autumn budget 2025 — Key business tax highlights – click here or here;
- Netherlands: 2026 Tax Plan adopted by lower house of Parliament, including Pillar Two changes and implementation of DAC9 – click here;
- Hungary: Autumn tax package adopted, including changes to global minimum tax rules – click here or here;
- Hungary: Hungary consults overhaul of transfer pricing documentation rules – click here;
- Sweden: Parliament approves amendments to interest deduction limitation rules – click here;
- Lithuania: Amendments to corporate income tax, VAT, excise taxes, and real estate tax, introduction of insurance premium tax – click here;
- Ireland: Irish Revenue updates guidance on anti-hybrid rules for partnerships – click here;
- Ukraine: Notification of updates to Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) positions – click here;
Global
- OECD: Public consultation on tax issues relevant to global mobility of individuals – click here;
- Global: 5 layers of a transfer pricing audit – click here;
- Global: Transfer pricing – PERCENTILE.INC vs PERCENTILE.EXC in Excel: Same data, different quartiles – click here;
- Australia: The Australian Taxation Office (ATO) issues guidance on Pillar 2 filing obligations – click here;
- Germany & United States: German tax authorities update view on reduced withholding tax (WHT) rates under Germany / United States tax treaty – click here;
- Cyprus & United States: Tax department issues guidance on bilateral country-by-country (CbC) reporting agreement with the United States – click here;
- Global: Good vs. bad transfer pricing – click here;
- Global: Report on ways to simplify taxation of cross-border business activities – click here;
- Global: Corporate Tax Statistics: report and related documents – click here;
- Global: Most transfer pricing teams still live in step 5 of this picture: documentation – click here;
- Global: Most transfer pricing local files are built the wrong way around – click here;
- Global: OECD Tax Certainty Day 2025 - consolidated information on mutual agreement procedures 2025 – click here;
- Global: OECD’s 2025 Model Tax Convention update: What it means for multinationals – click here;
- United States: Transfer pricing landscape shifts amid Internal Revenue Service (IRS) changes and tariffs – click here;
- Global: 2025 transfer pricing year in review – click here;
- India & Qatar: Income tax treaty between India and Qatar enters into force – click here;
- Global: How countries stack up in OECD’s 2024 Advance Pricing Agreement (APA) Statistics Report – click here;
- Global: Seven essential actions to strengthen your global Pillar Two readiness – click here;
- Uruguay: Proposed amendments to budget proposals, including Pillar Two minimum tax – click here;
- Honduras: Country-by-country report notification due December 31, 2025 – click here;
- Costa Rica: Updates to TRIBU-CR system for excise taxes, real estate capital gains withholding, and transfer pricing return due dates – click here;
- Kazakhstan: New controlled foreign corporations (CFC) forms; new whitelist of countries not considered to have preferential tax regimes – click here;
- Vietnam: Additional guidance on global minimum tax filing issued – click here;
- Taiwan: Ministry of Finance reminds businesses of Master File and country-by-country (CbC) report deadline – click here;
- Georgia: Georgia expands Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) coverage through 22 additional treaties – click here;
Romania
- Ionut Simion and Livia Teodoru (PwC) - A strategic tool in the relationship with NAFA, the Advance Pricing Agreement (APA) becomes even more important in the context of the second taxation package – click here;
- NAFA official about e-Invoice - ‘Accountants seem to have understood that it’s not a burden’ / ‘The entrepreneur should be the one to manage’ invoicing – click here;
- Ilie Bolojan (the Prime Minister), discussions with SMEs about eliminating the turnover tax - It will be a decision in support of companies – click here;
- ROMPAP (The Employers’ Association of the Pulp and Paper Industry) requested the elimination of the minimum turnover tax – click here;
- The Unconstitutionality of Extending Tax Limitation Periods through Emergency Ordinances No. 90/2020, 181/2020, and 226/2020 - From Exceptional Measures to an Abuse of Emergency Powers – click here;
- NAFA has successfully met two important targets from the National Recovery and Resilience Plan (NRRP) – click here;
- Adrian Nica (NAFA President) - “The perception that NAFA is not doing its job well enough is a correct one.”– click here;
TP Cases
- Hong Kong: Management fees paid to British Virgin Islands affiliate not deductible (Court of Appeal decision) – click here;
Webinars
- United Kingdom: Pillar Two – United Kingdom realities – click here for the podcast;
- Seminars organized by NAFA in December 2025 – click here.
