Europe

  • EU: CFE Tax Advisers Europe: 2025 Tax Policy Report – click here;
  • Switzerland: Zurich's transfer pricing practice adapted for the asset management industry – click here;
  • Cyprus: Increased local file thresholds for 2026 – click here;
  • Cyprus: Cyprus tax reform bills published– click here;
  • Germany: Germany to not initiate or renew tax advance pricing agreements (APAs) with China – click here;
  • Germany: Amendments to Pillar Two rules, DAC9, and DAC8 legislation enacted; other tax developments – click here;
  • Germany: Protocols to tax treaties with Netherlands and Switzerland enter into force – click here;
  • Sweden: Further amendments to Pillar Two legislation – click here;
  • Moldova: Moldova amends transfer pricing documentation requirements including new master file requirement – click here and here;
  • United Kingdom: His Majesty's Revenue and Custom (HMRC) updates Guidance for Compliance 7 (GfC7): Value chain analysis and offshore procurement hubs – what UK businesses need to know – click here;
  • Croatia: Implementation of DAC8 and DAC9 requirements – click here;
  • Croatia: Tax treaty with Australia signed, protocol to treaty with Switzerland ratified – click here;
  • France: User guide for GloBE information return (GIR) – click here;
  • France: Multiple reporting exemption regarding public country-by-country (CbC) reports transposed into law – click here;

Global

  • UN: UN releases new global guidance on key transfer pricing issues (i.e. agricultural products, BAPA, carbon offsets and carbon credits, pharmaceutical industry, Covid-19, compliance assurance) - click here;
  • Global: Tax treaty round up (January 2026) – click here;
  • Global: Asia Pacific financial services tax highlights – click here;
  • Global: Deloitte report: Testing the water: AI-enabled tax transformation – click here and here ;
  • OECD: Base Erosion and Profit Shifting Project - Tax challenges arising from the digitalisation of the economy – Global Anti-Base Erosion model rules (Pillar Two), Side-by-Side Package – click here;
  • Australia: Weekly tax round-up (27 January 2026) – click here;
  • Australia: The Australian Taxation Office (ATO) issues guidance on Pillar 2 Side-by-Side Package – click here;
  • Australia: Business structure – Understand the risks associated with structures and transactions that attract the Australian Taxation Office’s attention – click here;
  • Bahamas: Registration for domestic minimum top-up tax (DMTT) begins early 2026 – click here;
  • Bahrain: Domestic minimum top-up tax (DMTT) annual return now available – click here;
  • Japan: Japan Implementing Pillar 2 Side-by-Side Package – click here;
  • Hong Kong: Hong Kong tax review 2025 – click here;
  • Thailand: Pillar Two: Overview of current rules and draft secondary legislation – click here;

Romania

  • Operational Transfer Pricing - the advantages of switching from "TP file" to "real-time TP monitoring” – click here;
  • What the head of NAFA is looking closely at in 2026: a unified approach to transfer pricing and risk analysis, performance indicators for employees, staff rejuvenation, unjustified income of individuals, interventions before settlement procedures / mechanisms and putting SAF-T to work – click here;
  • The Ministry of Finance publishes in the “Transparency” section of its website the draft amendment of the Tax Procedure Code for the implementation of new European rules on tax cooperation – click here for the news and here for the Government Ordinance draft;
  • NAFA launches ANA - the taxpayers' virtual assistant – click here and here;
  • NACE codes Rev. 3, effective from 2026. News and deadlines for taxpayers – click here;
  • Switching from micro-enterprise tax to corporate income tax - steps to follow for changing the tax regime – click here;
  • Tax registration of business units. What changes, what risks arise and how to correctly apply the legislation – click here.
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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