brought to you by TPS
Europe
- Italy: Tax authorities publish Pillar Two GIR (GloBE Information Return) notification form – click here;
- Luxembourg: Luxembourg proposes legislation on GloBE Information Return, exchange of information and Administrative Guidance on Article 9.1 – click here;
- Ireland: Ireland's Pillar Two Hub and registration platform is live – click here;
- Channel Islands: Multinational corporate income tax (MCIT) registration requirements under Pillar Two (Jersey) – click here;
Global
- USA: OECD proposes changes to global tax deal to appease US – click here;
- USA: Tariffs underscore the need to true-up transfer pricing early – click here;
- USA: How do Trump tariffs 2.0 impact transfer pricing and vice versa? – click here;
- Thailand: Tariffs and transfer pricing: the friction ramps up – click here;
- Bahrain: Updated guidance on domestic minimum top-up tax (DMTT) – click here;
- Macau: Government unveils transfer pricing rules to close tax avoidance loopholes – click here;
Romania
- The Ministry of Finance has published the draft of the second package of fiscal measures (RO) – click here for the article and here for the draft;
- Draft: amendment to the Law on ensuring a minimum global level of taxation for multinationals (RO) – click here for the article and here for the draft;
- The new related parties tax vs. economic reality. Or how to further discourage investment (RO) – click here;
- Adrian Luca, Chamber of Tax Consultants: Retroactive extension of an advance pricing agreement is not a local invention (RO) – click here;
- ZF Live. Adrian Luca, Transfer Pricing Services: The new draft law on the taxation of multinationals penalizes any potential investment, is completely wrong, and shows a clear lack of economic fiscal strategy (RO) – click here;
- Ruxandra Tarlescu and Iulian Panfiloiu, PwC. Taxation of multinationals: more restrictive rules replace the minimum tax on turnover (RO) – click here;
- The Government intends to replace one fundamental error with another, according to a consultant. What is the new rule that is "unclear and contrary to OECD principles"? (RO) – click here;
- Finance Minister Alexandru Nazare's remarks at the press conference held on August 13 at the Government (RO) – click here;
- Analysis: Will Romania still join OECD? (RO) – click here;
- NAFA inspection at a call center: consulting services without clear economic substance are non-deductible expenses (RO) – click here;
TP Cases
- Ireland: Developments in the transfer pricing treatment of stock-based compensation – click here;
- Sweden: CJEU ruling gives helpful guidance on calculating VAT for intra-group services – click here for the article and here for the case;
- Tanzania: Tanzania vs Williamson Diamonds Limited, July 2025, Court of Appeal, Case No. 2025 TZCA 720 (Civil Appeal No 436 of 2023) – click here.
