brought to you by TPS
Europe
- Latvia: 2026 Transfer pricing overview in Latvia – click here;
- Luxembourg: Additional tax measures in law implementing DAC8 – click here;
- Luxembourg: Luxembourg implements Pillar One ‘Amount B’ simplified transfer pricing rules – click here;
- Liechtenstein: Consultation on implementation of Pillar Two side-by-side package and exchange of Global Anti-Base Erosion (GloBE) information returns – click here;
- France: France clarifies the Mutual Agreement Procedure (MAP) access rules, Advance Pricing Agreement (APA) roll-back conditions in transfer pricing guidance – click here;
- Hungary: Amendments to Global Anti-Base Erosion (GloBE) notification form – click here;
- Montenegro: Implementation of Pillar Two global minimum tax rules – click here;
- Georgia: New reporting obligation for international controlled transactions – click here;
- Finland: New guidance issued on application of Pillar Two safe harbor provisions – click here;
- Finland: Finland updated Foreign Account Tax Compliance Act (FATCA) and updated Common Reporting Standard (CRS) FAQs on implementation of CRS 2.0 – click here;
- The Netherlands: Public consultation on additional dividend stripping measures – click here;
- Italy: Guidance on application of elective alternative CFC (Controlled Foreign Company) tax – click here;
- Italy: “Commercial activity” requirement for participation exemption (Supreme Court decision) – click here;
- Ireland: Updated guidance on outbound payments defensive measures – click here;
- Turkiye: Türkiye proposed direct and indirect tax amendments, including formal cryptoasset taxation framework – click here;
- Austria & Uzbekistan: Austrian Council of Ministers authorizes signing of amending protocol to tax treaty with Uzbekistan – click here;
- Belgium & Kosovo: Tax treaty between Belgium and Kosovo signed – click here;
Global
- Global: KPMG article: Importance of aligning IP ownership with where value is created – click here;
- Global: KPMG article: Updated OECD manual on Mutual Agreement Procedures (MAPs) – click here;
- Australia: Australia updated guidance on transfer pricing for inbound distribution arrangements - click here and here;
- Bahamas: The Automatic Exchange of Information (AEOI) registration and reporting deadlines – click here;
- Global: PwC: Transfer pricing Q1 briefing – 2026 – click here;
- US: Internal Revenue Service (IRS) revives commensurate-with-income standard in transfer pricing - click here;
- Algeria: Algeria extends Corporate Income Tax (CIT), Personal Income Tax (PIT), transfer pricing filing deadlines for 2025 fiscal year – click here;
- Armenia & UK: UK publishes synthesized text of tax treaty with Armenia as impacted by the BEPS Multilateral Instrument (MLI) – click here;
- Brazil: Brazil’s Federal Revenue Service (RFB) consults substance-based tax incentive safe harbour rules – click here;
TP Cases
- Iceland: Transfer pricing assessment upheld based on incomplete taxpayer documentation (Court of Appeals decision) – click here;
- UK: Burlington: taxpayer wins again in treaty purpose test case – click here;
Romania
- Romania: Draft Order of the President of NAFA on the procedure for conducting the Mutual Agreement Procedure – click here, here and here for Adrian Luca | TPS Founding Partner’s opinion;
- Romania: NAFA proposes the procedure for conducting the Mutual Agreement Procedure. – click here;
- Romania: Head of NAFA advises companies: “We have introduced a pre-insolvency indicator. You should start looking at balance sheets and financial statements.” – click here;
- Romania: NAFA: Legislative Updates – Bulletin No. 14 of April 23, 2026 – click here;
- Romania: Law No. 52/2026 amending certain provisions of the Fiscal Procedure Code – click here.
