brought to you by TPS
Europe
- EU: Pillar Two compliance manual – click here;
- Belgium: Pillar Two: First Globe Information Return (GIR) notification deadline extended; final qualified domestic minimum top-up tax (QDMTT) and income inclusion rule (IIR) forms published – click here;
- Cyprus: Announcements on implementation of Pillar Two framework – click here;
- Liechtenstein: Income tax treaty with Belgium signed – click here;
- Malta: Protocol to tax treaty with San Marino enters into force – click here;
- Poland: Proposed windfall tax on liquid fuels, relaxation of procedural transfer pricing requirements; other tax developments – click here;
- United Kingdom: His Majesty’s Revenue and Customs (HMRC) consults draft International Controlled Transactions Schedule – click here;
Global
- OECD: OECD’s new Chapter VII: documentation matters, but transaction understanding comes first – click here;
- Australia: Memorandum of understanding on Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) arbitration process for taxes on income covered by income tax treaty with the Netherlands – click here;
- India: New safe harbour rules are prompting a reassessment of transfer pricing strategies – click here;
- Singapore: New FAQ on transfer pricing treatment of stock-based compensation costs – click here;
- Singapore: The Inland Revenue Authority of Singapore (IRAS) issues new guidance on tax treatment of related party payments – click here;
- Taiwan: Ministry of Finance clarifies reasonable interest on inter-company lending arrangements – click here;
Webinars
- Webinar: The role of contractual arrangements in transfer pricing, June 24th – click here;
- Webinar: From case law to practice: Managing transfer pricing for financial transactions, June 25th – click here;
Romania
- Romania: Draft of the new order regarding the transfer pricing file: more standardization and extended documentation requirements – click here;
- Romania: NAFA wants to radically change the transfer pricing rules: Large taxpayers will submit the file annually through SPV, and the threshold for services drops to EUR 100,000 – click here;
- Romania: The minimum corporate income tax of large multinationals – click here;
- Romania: The Ministry of Finance has published, in public transparency, a draft order approving the procedure for issuing advance individual tax rulings – click here and here;
- Romania: NAFA has established the method for conducting the Mutual Agreement Procedure – click here, here and here;
- Romania: NAFA videoconferencing platform: How discussions with the Tax Authorities about tax audits, hearings and other procedures will take place – click here.
