brought to you by TPS
Europe
- United Kingdom: His Majesty’s Revenue & Custom (HMRC) launches expanded “Transfer Pricing and Profit Diversion Compliance Facility” – click here;
- Germany: Draft bill for Annual Tax Act 2026 includes proposed Pillar Two, Country-by-Country Reporting (CbCR) changes; other tax developments – click here;
- Poland: Proposed legislation removing the Mandatory Disclosure Regime (MDR) obligations for domestic tax arrangements; guidance on correcting invoices and input VAT adjustments; other tax developments – click here;
- Luxembourg: Tax measures in European Commission (EC) tax simplification package most relevant to Luxembourg taxpayers – click here;
- Luxembourg: Updated Pillar Two FAQs – click here;
- Belgium: GloBE information return (GIR) portal opens June 29, 2026 – click here;
- Greece: Guidance on submission and exchange of GloBE Information Returns (GIRs) – click here;
- Sweden: Proposed amendments to Pillar Two Qualified Domestic Minimum Top-up Tax (QDMTT) rules – click here;
- Cyprus: Cyprus ratifies multilateral agreement on GloBE information exchange (GIR MCAA) – click here;
Global
- Canada: Extension of withholding tax relief for taxpayers reimbursing nonresident subcontractors – click here;
- United States: Internal Revenue Service (IRS) reviews Country-by-Country Reporting (CbCR) report exchange status, makes no changes – click here;
- Vietnam: Vietnam issues guidance on Country-by-Country Reporting (CbCR) reporting through automatic exchange of information – click here;
- Thailand: Government moves toward international exchange of GloBE information – click here;
TP Cases
- India: Payments received by U.S. company for web hosting services not royalties subject to withholding tax under U.S. treaty (tribunal decision); other direct and indirect tax developments – click here;
Webinars
- Webinar: The End of Cost-Plus 5% for Headquarters? OECD consultation paper points to value-based pricing and audit-ready transfer pricing documentation, July 9th – click here;
Romania
- Romania: Order No. 827 and Order No. 828, issued by the National Agency for Fiscal Administration (NAFA), were published in the Romanian Official Gazette No. 543 of 2 July 2026, introducing significant changes to the transfer pricing legislation. Order No. 828 updates the framework applicable to the transfer pricing documentation requirements and the transfer pricing adjustment/estimation procedures, while Order No. 827 revises the procedural framework governing the issuance and amendment of advance pricing agreements - click here;
- Romania: NAFA inspectors reclassify, for tax purposes, intra-group loans received by Romanian legal entities from non-resident affiliated entities, usually parent companies – click here and here;
- Romania: When NAFA recharacterizes intra-group loans as equity: uncertainty over the tax treatment of interest – click here;
- Romania: Royalties: Definition under the Tax Code and practical case study – click here;
- Romania: The Ministry of Finance updates the Tax Register: new written or electronic format for corporate income taxpayers – click here.
