brought to you by TPS
Europe
- Germany: Ministry of Finance (MOF) publishes draft guidance on permanent establishment criteria – click here;
- EU: CFE Opinion Statement on the EU Consultation on the DAC Recast – click here;
- EU: Taxation: Council updates the EU list of non-cooperative jurisdictions for tax purposes - click here;
- European Commission: European Commission consulting on initiative to simplify the existing EU legal direct taxation framework – click here;
- Finland: Guidance on global minimum tax, qualified domestic minimum top-up tax; legislation implementing DAC9 – click here;
- Denmark: Denmark updates SAF‑T 2.0 to support future transaction-level reporting and data sharing – click here;
- Ireland & Croatia: Ireland publishes synthesized text of tax treaty with Croatia as impacted by BEPS Multilateral Instrument (MLI) – click here;
- Latvia & Liechtenstein: Latvian parliament approves pending tax treaty with Liechtenstein – click here;
Global
- OECD: OECD releases Amount B Pillar One guidance, pricing automation tool – click here and here for the guidance;
- UN: Discussion of Protocol on Dispute Prevention and Resolution – click here;
- Bahrain: Updated guidance on domestic minimum top-up tax (DMTT) – click here;
- South Africa: Guidance on global minimum tax registration – click here;
- Singapore: Updated version of XML schema user guide for Common Reporting Standard (CRS) – click here;
- Canada: Canada signs multilateral competent authority agreement on the exchange of GloBE information – click here;
- France & India: Amending protocol to tax treaty between France and India signed – click here;
- India: Indian Tax Authority appeals order of Income Tax Appellate Tribunal that Multilateral Instrument (MLI) modifications must be formally notified to apply – click here;
- Philippines & Luxembourg: The Philippines and Luxembourg finalizing tax treaty – click here;
- Mauritius: Mauritius updates lists of reportable and participating jurisdictions for Common Reporting Standard (CRS) – click here;
- United Arab Emirates: UAE establishes single, comprehensive legislative framework supporting exchange of information upon request for tax purposes – click here;
- Venezuela: Advisers clash over Venezuela’s TP evolution in post-Maduro world – click here;
TP Cases
- Spain: Spanish Supreme Court clarifies beneficial ownership in Velcro royalty case – click here;
- Poland: Court rules deferred tax regime doesn’t exempt companies from transfer pricing rules – click here;
Romania
- Romania: How to determine your company’s fiscal risk classification – click here;
- Romania: Fiscal changes in 2026 for PFA (Authorized Natural Person) and SRL (Limited Liability Company) – click here;
- Romania: A new step forward for OECD accession: Romania accelerates in the field of open data – click here;
- Romania: Intra-group financial transactions under the lens of Article 9: what's new in the OECD's November 2025 update to the Model Convention and why it matters for Romania – click here.
