Europe

  • EU: Request for input on simplifying direct taxation rules. Feedback accepted until March 16, 2026 – click here;
  • Belgium: Trends to consider for 2026 transfer pricing audits – click here;
  • Hungary: Changes in the intra-group transactions: new transfer pricing decree – click here;
  • Bulgaria: Draft laws amending Corporate Income Tax Act, including Pillar Two clarifications – click here;
  • Poland: Consultation on proposed Pillar Two amendments; DAC8 legislation passed by Senate – click here;
  • Germany: Legislation increasing maximum amount for roll-over of hidden reserves in corporation shares enacted; other tax developments – click here;
  • Greece: Postponed implementation of mandatory e-invoicing for large businesses to March 2, 2026, with a transitional period until May 3, 2026 – click here;

Global

  • Global: Debt vs. equity – when does a loan stop being a loan? – click here;
  • Bahrain: Domestic Minimum Top-Up Tax (DMTT) compliance obligations – click here;
  • South Africa: Transfer pricing implications of transition to South African Rand Overnight Index Average Rate (ZARONIA) as key reference – click here;
  • France & India: Protocol signed to amend income tax treaty with France – click here;
  • United Kingdom & Peru: Income tax treaty with UK enters into force – click here;
  • Saudi Arabia: Consultation on economic substance regulations for special economic zones closing March 3, 2026 – click here;
  • Cote d’Ivoire: Provisions affecting nonresident digital businesses in 2026 budget – click here;
  • Singapore: Tax measures in budget 2026 – click here;
  • United Arab Emirates: Technical guidance on mandatory e-invoicing fields – click here;

TP Cases

  • United States: Partnership deduction disallowed because section 743(b) basis adjustment incorrectly calculated and related transactions lacked economic substance – click here;
  • United States: Is the tide still turned in U.S. transfer pricing litigation? – click here;
  • Mexico: Taxpayer advocate disagrees with tax authority’s position on deduction of advertising and promotional expenses – click here;
  • Kenya: Kenya’s Del Monte ruling underscores the need for robust transfer pricing frameworks – click here;
  • Poland: Real estate investment by family foundation qualifies for tax exemption; transfer pricing rules apply to taxpayers under Estonian Lump-Sum Tax on Corporate Income (CIT) scheme – click here;

Webinars

  • Webinar: Environmental, Social, and Governance (ESG) transformation and transfer pricing: strategic & operational implications, March 19, 2026 – click here;

Romania

  • Romania: Order on the approval of the model and content of the forms "Informative declaration regarding the GloBE Top-up Tax" and "Notification concerning the obligation to submit the informative declaration regarding the GloBE Top-up Tax" (pages 12-46) – click here;
  • Romania: Luca Niculescu (the coordinator of Romania's OECD accession process): "We hope that Romania's accession to the OECD will take place this year"/ Over 100 laws and procedures have been amended to date in support of this process – click here;
  • Romania: Warning regarding a fraud attempt through the use of a Link impersonating the interface of the NAFA Unified Contact Form – click here;
  • Romania: Tax consolidation has calmed markets, however the economy remains in a fragile stabilization, experts say – click here;
  • Romania: Tax ambiguities for companies – The new rules regarding the staggered payment of state liabilities generate confusion in practice – click here;
  • Romania: “NAFA’s inaction has encouraged practices such as the sale of indebted companies and even the emergence of businesses specialized in such schemes” (lawyer) – click here;
  • Romania: High tax risk among companies operating in the security and guard services sector – 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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