Europe

  • Latvia: 2026 Transfer pricing overview in Latvia – click here;
  • Luxembourg: Additional tax measures in law implementing DAC8 – click here;
  • Luxembourg: Luxembourg implements Pillar One ‘Amount B’ simplified transfer pricing rules – click here;
  • Liechtenstein: Consultation on implementation of Pillar Two side-by-side package and exchange of Global Anti-Base Erosion (GloBE) information returns – click here;
  • France: France clarifies the Mutual Agreement Procedure (MAP) access rules, Advance Pricing Agreement (APA) roll-back conditions in transfer pricing guidance – click here;
  • Hungary: Amendments to Global Anti-Base Erosion (GloBE) notification form – click here;
  • Montenegro: Implementation of Pillar Two global minimum tax rules – click here;
  • Georgia: New reporting obligation for international controlled transactions – click here;
  • Finland: New guidance issued on application of Pillar Two safe harbor provisions – click here;
  • Finland: Finland updated Foreign Account Tax Compliance Act (FATCA) and updated Common Reporting Standard (CRS) FAQs on implementation of CRS 2.0 – click here;
  • The Netherlands: Public consultation on additional dividend stripping measures – click here;
  • Italy: Guidance on application of elective alternative CFC (Controlled Foreign Company) tax – click here;
  • Italy: “Commercial activity” requirement for participation exemption (Supreme Court decision) – click here;
  • Ireland: Updated guidance on outbound payments defensive measures – click here;
  • Turkiye: Türkiye proposed direct and indirect tax amendments, including formal cryptoasset taxation framework – click here;
  • Austria & Uzbekistan: Austrian Council of Ministers authorizes signing of amending protocol to tax treaty with Uzbekistan – click here;
  • Belgium & Kosovo: Tax treaty between Belgium and Kosovo signed – click here;

Global

  • Global: KPMG article: Importance of aligning IP ownership with where value is created – click here;
  • Global: KPMG article: Updated OECD manual on Mutual Agreement Procedures (MAPs) – click here;
  • Australia: Australia updated guidance on transfer pricing for inbound distribution arrangements - click here and here;
  • Bahamas: The Automatic Exchange of Information (AEOI) registration and reporting deadlines – click here;
  • Global: PwC: Transfer pricing Q1 briefing – 2026 – click here;
  • US: Internal Revenue Service (IRS) revives commensurate-with-income standard in transfer pricing - click here;
  • Algeria: Algeria extends Corporate Income Tax (CIT), Personal Income Tax (PIT), transfer pricing filing deadlines for 2025 fiscal year – click here;
  • Armenia & UK: UK publishes synthesized text of tax treaty with Armenia as impacted by the BEPS Multilateral Instrument (MLI) – click here;
  • Brazil: Brazil’s Federal Revenue Service (RFB) consults substance-based tax incentive safe harbour rules – click here;

TP Cases

  • Iceland: Transfer pricing assessment upheld based on incomplete taxpayer documentation (Court of Appeals decision) – click here;
  • UK: Burlington: taxpayer wins again in treaty purpose test case – click here;

Romania

  • Romania: Draft Order of the President of NAFA on the procedure for conducting the Mutual Agreement Procedure – click here, here and here for Adrian Luca | TPS Founding Partner’s opinion;
  • Romania: NAFA proposes the procedure for conducting the Mutual Agreement Procedure. – click here;
  • Romania: Head of NAFA advises companies: “We have introduced a pre-insolvency indicator. You should start looking at balance sheets and financial statements.” – click here;
  • Romania: NAFA: Legislative Updates – Bulletin No. 14 of April 23, 2026 – click here;
  • Romania: Law No. 52/2026 amending certain provisions of the Fiscal Procedure Code – 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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