brought to you by TPS
Europe
- United Kingdom: HM Revenue & Customs publishes updated and new guidance manuals – click here;
- Germany: Transaction matrix requirement is reshaping transfer pricing compliance – click here;
- Belgium: Pillar Two compliance guidance, including final Pillar Two returns and implementation of DAC9 – click here;
Global
- OECD: Public consultation draft on intra-group services: Revolution or Evolution? (BPO opinion) – click here;
- OECD: Global minimum tax: Practical fixes to global anti-base erosion (GloBE) information return (GIR) XML schema for first filings – click here for the press release and here;
- Global: CFE’s Tax Top 5 – 8 June 2026 – click here;
- Global: Transfer Pricing in Practice (Quantera Global article) – click here;
- Australia: Weekly tax round-up (9 June 2026) – click here;
- Australia: Global anti-base erosion (GloBE) Information Return (GIR) XML file requirements – click here;
- Australia: Reminder: First Pillar Two lodgments due 30 June 2026 – click here;
- Australia: Public country-by-country (CbC) report overview – click here and here;
- Kuwait: Kuwait approves accession to Base Erosion and Profit Shifting (BEPS) multilateral convention – click here;
- Bahrain: Bahrain publishes transfer pricing guidance for Multinational Enterprises – click here;
- Singapore: Singapore updates transfer pricing guidance on share-based compensation under the Transactional Net Margin Method (TNMM) – click here;
- Vietnam: Summary of recent direct and indirect tax developments, including clarification on eligible payroll costs for substance-based income exclusion calculation under qualified domestic minimum top-up tax (QDMTT) – click here;
- Panama: New economic substance law for foreign-source passive income, effective starting in 2027 fiscal year – click here;
TP Cases
- United Kingdom: Lifeplus Europe Ltd v The Commissioners for HMRC decision: The UK First-tier Tribunal (FTT) finds documents not reasonably required as part of transfer pricing enquiry – click here for the press release and here for the case description and court judgment;
- Australia: Transfer of shares within corporate group not entitled to corporate reconstruction stamp duty relief (Queensland Court of Appeal decision) – click here for the press release and here for the Queensland Court of Appeal decision;
- India: Global procurement services from foreign group entity were not intermediary services for Goods and Services Tax (GST) purposes (tribunal decision) - Dow Chemical International Private Limited, 2026-VIL-26-GSTAT-DEL – click here;
- India: Indian company’s reimbursements to its U.S. subsidiary for online advertising expenses not subject to equalization levy (High Court decision) – click here;
- Europe: PwC article: The effect of the Stellantis case on intragroup adjustments – from transfer pricing to VAT – click here;
Webinars
- Webinar: The role of contractual arrangements in transfer pricing: Insights from case law and practice, June 24, 4:00 pm - 5:00 pm CET – click here;
Romania
- Romania: Draft order of the President of NAFA for the approval of the procedure regarding the issuance and modification of the advance pricing agreement, as well as the content of the request for issuance and modification of the advance pricing agreement – click here for the download link, here for the press release, and here for Adrian Luca | TPS Founding Partner’s opinion;
- Romania: Draft order of the President of NAFA regarding the amount of transactions, the deadlines for preparation, the content and conditions for requesting the transfer pricing file and the procedure for adjusting/estimating transfer prices – click here or here for the download link, and here for Adrian Luca | TPS Founding Partner’s opinion;
- Romania: Adrian Luca | TPS Founding Partner: Opinion on the proposal to supplement art. 25 of the Fiscal Code: “The OECD says that the tax authorities have no role to dictate to a company where they get their services from. In the same period, a bill in the Senate wants to make all these intra-group services simply non-deductible, from January 1, 2027. One is one, another is another.” – click here;
- Romania: Four new rules for distributing dividends and granting loans for loss-making companies: Law no. 239/2025 – click here for the press article and here for the NAFA press release;
- Romania: Deloitte article: What do the latest NAFA decisions say about the risks related to transfer pricing? – click here;
- Romania: NAFA legislative news - bulletin no. 20 of June 5, 2026 – click here;
- Romania: Waiving the loan granted by the associates to the company. What is the tax-accounting treatment of that amount? – click here.
