brought to you by TPS
Europe
- Belgium: Ruling Commission introduces electronic delivery of tax rulings – click here;
- Belgium: Tax authorities clarify updated Base Erosion and Profit Shifting (BEPS) 13 transfer pricing forms and Country-by-Country (CbC) reporting – click here;
- France: France tax authorities (FTA) issues new guidelines on extension of exceptional temporary surtax – click here;
- United Kingdom: UK proposes compulsory foreign permanent establishment exemption from 2027 – click here;
- Sweden: Sweden proposes direct Pillar Two top-up tax liability for joint ventures – click here;
- Ukraine: Substantial update to transfer pricing rules: Cabinet of Ministers of Ukraine approved draft law – click here;
- Portugal: Portugal extends Pillar Two Modelo 62 filing deadline for 2025 tax year – click here;
Global
- Malaysia: Recent tax developments concerning indirect tax, transfer pricing, and e-invoicing – click here;
- United States: Internal Revenue Service (IRS) accepting applicants for 2027 Compliance Assurance Process (CAP) program beginning September 8 – click here;
- Taiwan: Taiwan reminds businesses of cross-border e-service tax duties – click here;
- Australia: Australia enacts corporate tax loss carry-back rules – click here;
- Philippines: The Philippines Department of Finance (DoF) consults on ProGRESS tax reform bill incorporating global minimum tax – click here;
- Bahrain: Bahrain’s National Bureau for Revenue (NBR) updates guidance on Domestic Minimum Top-up Tax (DMTT) returns – click here;
- Uruguay: Uruguay replaces Pillar Two Qualified Domestic Minimum Top-Up Tax (QDMTT) exemption with compensation mechanism – click here;
- Brazil: Brazil revises tax code with alternative dispute resolution framework, new penalty caps – click here;
- Panama: Panama introduces economic substance rules for multinational entities from 2027 – click here;
- Singapore: Inland Revenue Authority of Singapore (IRAS) updates guidance on financial year-end changes – click here;
- Australia: Guidance on treatment of cross-border payments as royalties for withholding tax purposes; memorandum of understanding (MoU) with France on treaty arbitration process under Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) – click here;
- UAE: The introduction of the 15% minimum tax reduces the attractiveness of structures driven primarily by tax advantages and is prompting multinational groups to reassess their presence in the UAE – click here;
TP Cases
- India: Karnataka High Court: Transfer Pricing Officer cannot reject taxpayer comparables for Departament’s standard set – click here;
- Israel: Supreme Court remands related-party intellectual property valuation case for independent expert opinion – click here;
- India: The Bangalore Income Tax Appellate Tribunal (ITAT) held that no notional interest adjustment is warranted on delayed receivables from related parties where the taxpayer is debt-free and there is no evidence of financing costs or a financing arrangement – click here;
- India: The Bangalore Income Tax Appellate Tribunal (ITAT) deleted the notional interest adjustment on outstanding related-party receivables, as the relevant invoices were not overdue at year-end, and also ordered the exclusion of several functionally non-comparable companies from the benchmarking analysis – click here;
- India: The Mumbai Income Tax Appellate Tribunal (ITAT) deleted a transfer pricing adjustment on interest paid on non-convertible debentures, holding that the transfer pricing officer could not apply an ad hoc 10-year maturity filter without demonstrating its economic relevance to the transaction – click here;
- India: The Delhi Income Tax Appellate Tribunal (ITAT) rejected the application of a mechanical 50% turnover filter and held that transfer pricing adjustments should be restricted to international transactions with associated enterprises, while also allowing certain comparability adjustments – click here;
Webinars
- Webinar: Seminars organized by NAFA in September 2026 – click here;
