brought to you by TPS
Europe
- Switzerland: Guidance on application of Pillar Two side-by-side package – click here;
- Malta: Updated guidance on Pillar Two rules, including delayed application of income inclusion rule (IIR) and undertaxed profits rule (UTPR) – click here;
- Germany: Ministry of Finance (MoF) issues draft amendments to Minimum Tax Implementation Ordinance – click here;
- Cyprus: Low-tax jurisdictions for tax year 2026 – click here;
- France: Reduced corporate income tax (CIT) rate: the turnover criterion revised for companies belonging to groups – click here;
- Italy: Italian Revenue Agency approves technical specifications and procedures for global minimum tax return and GloBE information return – click here;
- The Netherlands: Netherlands implements DAC8 requirements – click here;
- Turkey: Turkey issues draft forms, guidance for Pillar Two global minimum tax – click here;
- Finland: Finland addresses group identification, income allocation in new guidance on Minimum Tax Act – click here;
Global
- OECD: Update on international tax cooperation provided to G20 finance ministers (April 2026) – click here for the article and here to read the report;
- OECD: Updated signatories of the multilateral competent authority agreement on the exchange of GloBE (Global Anti-Base Erosion Rules) information – click here;
- USA: Increased advance pricing agreement demand puts pressure on Advance Pricing and Mutual Agreement (APMA) Program – click here;
- USA: Inside the 2025 Internal Revenue Service (IRS) APMA statistics – click here;
- Kuwait: Guidance on application of 5% tax retention rules to taxpayers within scope of domestic minimum top-up tax (DMTT) – click here;
- Australia: Navigating Australia's new Public Country-by-Country Reporting (PCbCR) landscape: What multinationals need to know, now! – click here;
- New Zealand: Inland Revenue clarifies transfer pricing documentation expectations – click here and here;
- UAE: Federal Tax Authority (FTA) issues revised rulings framework covering APAs, tax transaction directives – click here;
TP Cases
- Romania & France: KPMG in Romania secures a reduction in a transfer pricing adjustment through a favorable resolution of a mutual agreement procedure (MAP) between Romania and France – click here;
- Italy: Italian Supreme Court ruling on cash pooling and arm’s length principle – click here;
- Italy: Cost contribution arrangements – a key clarification on deductibility of intra-group costs – click here;
- Portugal: case involving the appropriateness of performing working capital adjustments between a limited-risk distributor and independent comparables – click here;
Webinars
- Webinar: Public CbCR readiness: Preparing for EU and Australia public reporting, April 30 – click here.
Romania
- Romania: The new reality of tax inspections: real-time data analysis and documentation – click here;
- Romania: The minimum amount of outstanding tax liabilities for which a list of debtors is published – click here;
- Romania: The Bermuda triangle of Romanian taxation: 5-year archiving vs. extension of the statute of limitations via emergency ordinance vs. Article 110 of the Tax Procedure Code. Which will prevail? – click here;
- Romania: NAFA announces a radical reorganization: centralized inspections, the use of AI in inspections, and hunting for unexplained wealth – click here;
