brought to you by TPS
Europe
- France: France strengthens transfer pricing rules under 2024 Finance Act – click here;
- France: Tax authority issues guidance on Pillar 2 global minimum tax – click here;
- UK: The UK government published Finance (No. 2) Bill 2024-26 (“the Finance Bill”) containing legislation to reform the UK’s transfer pricing, permanent establishments, and diverted profits tax (DPT) legislation – click here;
- Cayman Islands: Country-by-Country Reporting (CbCR) now available on the Department for International Tax Cooperation (DITC) portal, 2024 Country-by-Country Reporting (CbCR) reporting deadline extended – click here;
- Cayman Islands: Common Reporting Standard (CRS) regulatory amendments published – click here;
- Switzerland: KPMG article: Survey on application of control of risk and development, enhancement, maintenance, protection, and exploitation (DEMPE) frameworks, focus on Switzerland – click here;
- Poland: Poland tightens transfer pricing enforcement: financing under the microscope – click here;
- Cyprus: Tax Department clarifies bilateral agreement with US for exchange of Country-by-Country (CbC) reports – click here;
Global
- OECD: More jurisdictions commit to automatic exchange of information, new reports released – click here;
- USA: A group consisting of China, Estonia, Poland, and the Czech Republic has blocked the publication of documents prepared by OECD on new global minimum tax rules, challenging the G7's plans to grant large exemptions to US corporations – click here;
- Australia: Australia’s transfer pricing scrutiny calls for litigation prep– click here;
- Australia: Australian Taxation Office (ATO) administrative approach to public country-by-country reporting exemptions – click here and here;
- Singapore: Legislative changes focus on Pillar Two – click here;
- Qatar: General Tax Authority (GTA) launches ‘Tabadol’ portal for Country-by-Country (CbC) reports – click here;
- Argentina: Argentina’s tax and customs agency (ARCA) consults draft transfer pricing regulation – click here;
- Tunisia: Tunisia mandates electronic submission of tax returns, transfer pricing declaration – click here;
- Tunisia: Tunisia’s tax administration has issued a notice reminding taxpayers of their obligation to submit Country-by-Country (CbC) reports for the 2024 fiscal year by 31 December 2025 – click here;
- Algeria: Algeria gazettes mutual assistance convention – click here;
Romania
- NAFA's campaign on Country-by-Country Reporting (CbCR) - last month for voluntary compliance – click here;
- The Constitutional Court of Romania rejected the complaints of unconstitutionality against the fiscal measures law in the second package of measures to stabilize the country's finances, which means that the measures can come into force on January 1, 2026, as planned by the Government – click here;
- How to handle unexpected tax inspections – click here;
- Prime Minister Ilie Bolojan announced that he hopes the Government will make a decision on the turnover tax by Christmas, along with the extension of measures or even the cancellation of other measures, in preparation for next year's budget – click here;
- Romania transposes DAC8 Directive into national law – click here;
TP Cases
- India: Netflix India transfer pricing ruling boosts investor confidence – click here;
- India: “At-cost” transfer pricing model upheld for provision of technical services in oil and gas operations (tribunal decision) – click here;
- Germany: Obligation to disclose emails in tax audits (court decision) – click here;
- Belgium: KPMG report: Transfer pricing implications of the Court of Justice of the European Union (CJEU) judgment on application of VAT to cross-border intra-group services – click here;
- Czech Republic: Intriguing case concerning TP consequences of a business restructuring – click here;
- France: Judgment of the Paris Administrative Court on MAP access – click here.
