brought to you by TPS
Europe
- Republic of Moldova: Repeated tax inspections related to transfer pricing: what will change starting with 2027 and how taxpayers in the Republic of Moldova can prepare – click here;
- Slovakia: Guidance on establishment of “classic” permanent establishment (PE) – click here;
- Belgium: Law implementing DAC9, extending statutory domestic top-up tax (DTT) return filing deadline adopted by Parliament – click here;
- Poland: Package of tax legislation passed by lower house of Parliament; other tax developments – click here;
- Cyprus: Tax Department revises transfer pricing simplification return rates from 2026 – click here;
- Ukraine: Ukraine proposes Anti-Tax Avoidance Directive (ATAD) aligned anti-avoidance rules to combat aggressive tax planning – click here;
- Montenegro: Montenegro approves negotiation of new tax treaty with Romania – click here and here;
- Switzerland: Federal Council amends minimum tax rules to delay OECD guidance – click here;
Global
- Global: PwC transfer pricing Q3 2026 briefing – click here;
- OECD: Pillar Two: revised global anti-base erosion information return (GIR) XML schema and user guide released – click here and here;
- Africa: KPMG article: African firms struggle to find good transfer pricing comparables – click here and here;
- Singapore: Administrative concession for prior transfer pricing treatment of share-based compensation costs – click here;
- South Africa: South Africa proposes special economic zone (SEZ) transfer pricing reforms, corporate tax changes in medium-term budget policy – click here;
TP Cases
- Netherlands: Advocate General (AG) opines Dutch tax exemption precludes “double taxation” under EU tax dispute rules – click here;
- Czech Republic: Czech Republic vs Inventec (Czech), s. r. o., October 2026, Supreme Administrative Court, Case No 10 Afs 245/2025 – 56 – click here;
- Germany: Local tax court narrows scope of royalty barrier – click here;
- Spain: The price of products purchased from the group may implicitly include a royalty for the use of intangible assets, subject to a nonresident income tax withholding – click here;
Romania
- Romania: Legislative proposal update: lawyers won’t be mandatory for drafting contracts, the initiators explain – click here;
- Romania: EY Romania survey: 7 out of 10 companies have not tested their readiness for the new generation of tax inspections – click here;
- Romania: Pre-insolvency seizures by NAFA are on the way. Tax officials receive alerts via an app if a company is at risk of insolvency and must act quickly to recover debts owed to the state – click here;
- Romania: The transfer pricing file in the banking sector: between NAFA's Order and the Basel III/IV prudential requirements – click here.
