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Europe
- EU: European Commission launches public consultation on the Directive on Administrative Cooperation (DAC) recast proposal, including changes to DAC6 reporting requirements; consultation closes on 1 December 2026 – click here and here to read the draft.
- Poland: Proposed changes to transfer pricing regulations, including specific rules for financial transactions and compensating adjustments – click here and here;
- Bulgaria: Tax procedure code amended to implement DAC8 and DAC9 and to revise transfer pricing rules – click here;
- Belgium: Belgium launches Base Erosion and Profit Shifting (BEPS) 13 Local File XML creator tool; Local File filing deadline extended to 10 November 2026 – click here;
- Luxembourg: Public country-by-country (CbC) reporting – what non-EU groups need to know before filing in Luxembourg – click here;
Global
- OECD: Ninth peer review on country-by-country (CbC) reporting – click here;
- Kuwait: Kuwait gazettes Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) – click here;
- Ghana: Country-by-country (CbC) reporting – currency depreciation expands the compliance net for multinationals, as the filing threshold is set in Ghana cedi – click here;
TP Cases
- United States: United States vs Facebook, Inc. and Subsidiaries, September 2026, United States Tax Court, Case No 21959-16 (167 T.C. No. 12) – click here;
Webinars
- OECD: Tax Certainty Day 2026, 4th of November 2026 (release of the 2025 mutual agreement procedure (MAP) and advance pricing agreement (APA) statistics); registration by 26 October 2026 – click here;
Romania
- Romania: The Senate adopts draft law L481/2026 limiting the deductibility of intra-group management, consulting, assistance and intellectual property expenses and capping interest on intra-group financing; the bill goes to the Chamber of Deputies for the final vote – click here and here;
- Romania: Niculescu Cabinet’s governing programme: stricter inspections on artificial profit shifting through intra-group services, royalties and financing, and revision of the fees for issuing and amending advance pricing agreements (APAs) – click here and here and here;
- Romania: Global minimum tax (Pillar Two): how it works, key deadlines and how it is transforming the tax function; large groups should already prepare for the 31 March 2027 filing deadline – click here;
- Romania: National Agency for Fiscal Administration (NAFA) trains its management on new digital tools, including the SFERA system centralising tax databases and the APIC/Big Data platform used for risk analysis – click here.
