brought to you by TPS
Europe
- Slovenia: Pillar Two tax returns published – click here;
- Malta: Exemption for local group members from filing GloBE information return (GIR) and related notifications – click here;
- EU: Prior Belgian controlled foreign company (CFC) rules incompatible with ATAD (CJEU judgment) – click here;
- Netherlands: Netherlands issues tax guidance on permanent establishment requirements under Minimum Tax Act – click here;
- Montenegro: Parliament approves Pillar Two global minimum tax – click here;
- Sweden: Sweden consults research & development tax incentives under Pillar Two, aligns with Side-by-Side Package – click here;
- United Kingdom: UK’s Tax Authority, HM Revenue & Customs (HMRC) updates guidance on qualified income inclusion rule (IIR), Qualified Domestic Minimum Top-up Tax (QDMTT) jurisdictions – click here;
- Ukraine: Ministry of Finance (MoF) consults transfer pricing reform bill – click here;
- Georgia: Georgia introduces reporting obligations for international controlled transactions exceeding GEL 500,000 – click here;
Global
- OECD: OECD Master File-Concept and (Country-by-country) CbC-Reporting – international documentation requirements – click here;
- OECD: Global forum on transparency publishes 2026 report on capacity-building activities – click here;
- OECD: OECD and Institute for Sustainable Development (IISD) agree to strengthen cooperation on domestic resource mobilization – click here;
- OECD: Amount B pricing FAQs, updated Amount B pricing automation tool – click here;
- Korea: Domestic minimum top-up tax enacted – click here;
- Australia: Amendments to global minimum tax rules in line with GloBE rules – click here or here;
- Australia: Finalized public country-by-country (CbC) reporting filing instructions, updated guidance – click here;
- Qatar: Pillar Two resolution provides rules for applying qualified domestic minimum top-up tax (QDMTT) and income inclusion rule (IIR) – click here;
- Japan: Cabinet introduces Side-by-Side Package in 2026 tax reform bill – click here;
- United States: Proposed regulations – removal of final regulations identifying certain partnership basis shifting transactions of interest – click here;
- United States: Navigating complex tax compliance- What large businesses need to know this tax season – click here;
TP Cases
- Romania: Remontada and final victory before the Ploiesti Court of Appeal for Radu Taracila Padurari Retevoescu SCA (RTPR)'s tax litigation team for Rosti Romania SRL | The adjustment of the tax loss made by estimation was held to be unlawful; the transfer pricing file, which had not been challenged by the tax authorities, should have been taken into account – click here;
- Czech Republic: Czech Regional Court Annuls Transfer Pricing Adjustment in Hitachi Astemo Case – click here;
- Iceland: Court of Appeals rule taxpayers must prove arm’s length pricing in related-party deals – click here;
Romania
- Romania: NAFA documentary verification: The legal framework is "deficient" and "insufficiently regulated". What entrepreneurs need to know – click here;
- Romania: NAFA reorganizes the Tax Inspection Directorate following the Anti-Fraud model. Control plans will be issued centrally, based on risk analysis, and a new structure will review tax inspection reports – click here;
- Romania: Update indicates that Romania has signed Multilateral Competent Authority Agreement on Automatic Exchange of Information on Income Derived Through Digital Platforms (DPI MCAA) – click here;
- Romania: NAFA carried out over 33,800 tax audits in 2025, up by 7.2% compared to 2024 – click here.
