brought to you by TPS
Europe
- Germany: The German Ministry of Finance (MOF) issues draft proposal of Annual Tax Act 2026 seeking input from stakeholders – click here;
- Cyprus: Pillar 2 Global Minimum Tax Directive: new frequently asked question (FAQ) available – click here and here;
- United Kingdom: The UK’s transfer pricing landscape is entering a new era of scrutiny – click here;
- Turkiye: Law introducing tax reforms approved by Parliament – click here;
- Greece: Law clarifying Pillar Two rules, implementing DAC8 and DAC9 enacted – click here;
- Ireland: Guidance on global anti-base erosion information return (GIR) filing and notification requirements under Pillar Two – click here;
- Poland: Bill amending mandatory disclosure rules approved by lower house of Parliament – click here;
- Poland: Act introducing amendments to tax code passed by lower house of Parliament; other tax developments – click here;
- Hungary: Final tax declaration Form 24GLBADO for qualifying domestic minimum top-up tax – click here;
- Spain: Proposed amended list of non-cooperative jurisdictions includes removal of Gibraltar – click here;
- Czech Republic: Simplification of top-up tax information returns confirmed – click here;
- Luxembourg: Guidance on Amount B simplified transfer pricing approach – click here;
Global
- OECD: Public consultation on taxation: Revisions to Chapter VII of the OECD Transfer Pricing Guidelines – click here and here;
- OECD: Revision of Chapter VII of the OECD Guidelines: Changes in the approach to intra-group services within both transfer pricing documentation and tax audits – click here;
- Global: PwC: Beyond cost-plus – OECD rewrites the rules on intra-group services – click here;
- Global: CFE’s Tax Top 5 – 1 June 2026 – click here;
- Barbados & Cyprus & Czech Republic & Romania: Update indicates that four additional jurisdictions have signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) – click here;
- Panama: Economic substance requirements for foreign-source passive income become law – click here and here;
- Malaysia & Maldive: Income tax treaty with Maldives enters info force – click here;
- Turkiye & Zambia: Income tax treaty with Zambia signed – click here;
- Bolivia: Bolivia’s National Tax Service (SIN) further extends 2025 filing deadline for financial statements, transfer pricing documentation – click here;
- Bolivia: Bolivia updates list of low-tax jurisdictions for transfer pricing, tax control purposes – click here;
- Canada: The Canada Revenue Agency (CRA) releases updated 2025 corporate income tax guide – click here;
- Indonesia: Administrative guidelines under Pillar Two rules – click here and here;
- Japan: National Tax Agency updates Country-by-Country (CbC) exchange jurisdictions list – click here;
TP Cases
- India: India vs Inductotherm (India) Pvt. Ltd., May 2026, Income Tax Appellate Tribunal, Case No ITA No. 1609/Ahd/2024 – click here;
- Italy: Italy vs Illva Saronno SpA, May 2026, Supreme Court, Case No 15698/2026 – click here;
- Portugal: Portugal vs “Bank Branch”, May 2026, Supreme Administrative Court, Case No 02070/09.7BELRS.SA1 – click here;
Romania
- Romania: NAFA verified intra-group transactions worth over RON 199 billion – click here, here and here;
- Romania: A European Union official says Romania could manage without new taxes: “I am not sure they will be necessary'" – click here;
- Romania: NAFA audits: Two case studies showing exactly what tax inspections are targeting in 2026 – click here;
- Romania: Inactive company: Requirements for reducing share capital when net assets drop below the legal limit – click here.
