brought to you by TPS
Europe
- EU: The European Commission is calling on some member states to complete the transposition of the tax information exchange rules – click here;
- EU: The European Commission is calling on some member states to align their legislation on dividend taxation – click here;
- UK: Mandatory overseas permanent establishment exemption - draft legislation published – click here and here;
- France: Decree clarifies format for publication of public country-by-country (CbC) report – click here and here;
- France: Pillar Two: First GloBE information return (GIR) filing deadline extended until 1 September 2026 for the fiscal year (FY) closed on 31 December 2024 – click here;
- Lithuania: Lithuania consults transfer pricing documentation, arm’s length range draft guides – click here;
- The Netherlands: Dutch tax rulings shift toward bilateral and multilateral advance pricing agreements (APAs) – click here;
- Croatia: Global minimum tax implementing regulations – click here;
- Norway: Consultation on Pillar Two safe harbour amendments – click here;
- Turkiye: Pillar Two filing opened for global minimum top-up tax – click here;
- Belgium: Guidance on notification of GloBE information return (GIR) filing entity, portal opened – click here;
- Greece: Extension of Pillar Two top-up tax returns filing deadline and launch of GloBE information return (GIR) platform – click here;
Global
- OECD: Updated economic impact assessment and working paper on multinational enterprises responses to global minimum tax (GMT) released – click here and here;
- OECD: Proposed targeted amendments to the Model Reporting Rules for Digital Platforms to support exchange of tax information – click here;
- Panama: New transfer pricing reporting Form 930 version 3, effective July 1, 2026 – click here;
- Vietnam: New guidance on tax treaties, mutual agreement procedures, and advance pricing arrangements, effective July 1, 2026 – click here;
- Malaysia: Tax developments focusing on transfer pricing, e-invoicing, and investment incentives (July 2026) – click here;
- Australia: Updated guidance addressing global and domestic minimum tax filing obligations – click here;
TP Cases
- Romania: A novel solution in the tax procedure: the illegality of the tax inspection notice entails the illegality of the entire tax inspection – click here;
- Romania: High Court of Cassation and Justice: Loans granted to an affiliated company – click here and here;
- Portugal: CJEU. C-603/24 | Stellantis Portugal. VAT treatment of intra-group transfer pricing adjustments for motor vehicles – click here;
Romania
- Romania: Transfer pricing is entering a new phase: the transfer pricing file will no longer be “shelved,” but will be submitted in the Virtual Private Space (SPV). “The first sign that a company is not in good standing is that it is reporting losses and high volumes.” – click here;
- Romania: NAFA is requesting data on crypto transactions, but no one is telling companies how to report them, explains a law firm – click here;
- Romania: NAFA Order No. 828/2026: Come join a unique TPSoccer training session (with surprises!) and the transfer pricing seminar! – click here;
- Romania: NAFA is updating the “Invitation to a hearing” form, used as part of its document review process – click here;
