Europe

  • Belgium: Ruling Commission introduces electronic delivery of tax rulings – click here;
  • Belgium: Tax authorities clarify updated Base Erosion and Profit Shifting (BEPS) 13 transfer pricing forms and Country-by-Country (CbC) reporting – click here;
  • France: France tax authorities (FTA) issues new guidelines on extension of exceptional temporary surtax – click here;
  • United Kingdom: UK proposes compulsory foreign permanent establishment exemption from 2027 – click here;
  • Sweden: Sweden proposes direct Pillar Two top-up tax liability for joint ventures – click here;
  • Ukraine: Substantial update to transfer pricing rules: Cabinet of Ministers of Ukraine approved draft law – click here;
  • Portugal: Portugal extends Pillar Two Modelo 62 filing deadline for 2025 tax year – click here;

Global

  • Malaysia: Recent tax developments concerning indirect tax, transfer pricing, and e-invoicing – click here;
  • United States: Internal Revenue Service (IRS) accepting applicants for 2027 Compliance Assurance Process (CAP) program beginning September 8 – click here;
  • Taiwan: Taiwan reminds businesses of cross-border e-service tax duties – click here;
  • Australia: Australia enacts corporate tax loss carry-back rules – click here;
  • Philippines: The Philippines Department of Finance (DoF) consults on ProGRESS tax reform bill incorporating global minimum tax – click here;
  • Bahrain: Bahrain’s National Bureau for Revenue (NBR) updates guidance on Domestic Minimum Top-up Tax (DMTT) returns – click here;
  • Uruguay: Uruguay replaces Pillar Two Qualified Domestic Minimum Top-Up Tax (QDMTT) exemption with compensation mechanism – click here;
  • Brazil: Brazil revises tax code with alternative dispute resolution framework, new penalty caps – click here;
  • Panama: Panama introduces economic substance rules for multinational entities from 2027 – click here;
  • Singapore: Inland Revenue Authority of Singapore (IRAS) updates guidance on financial year-end changes – click here;
  • Australia: Guidance on treatment of cross-border payments as royalties for withholding tax purposes; memorandum of understanding (MoU) with France on treaty arbitration process under Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) – click here;
  • UAE: The introduction of the 15% minimum tax reduces the attractiveness of structures driven primarily by tax advantages and is prompting multinational groups to reassess their presence in the UAE – click here;

TP Cases

  • India: Karnataka High Court: Transfer Pricing Officer cannot reject taxpayer comparables for Departament’s standard set – click here;
  • Israel: Supreme Court remands related-party intellectual property valuation case for independent expert opinion – click here;
  • India: The Bangalore Income Tax Appellate Tribunal (ITAT) held that no notional interest adjustment is warranted on delayed receivables from related parties where the taxpayer is debt-free and there is no evidence of financing costs or a financing arrangement – click here;
  • India: The Bangalore Income Tax Appellate Tribunal (ITAT) deleted the notional interest adjustment on outstanding related-party receivables, as the relevant invoices were not overdue at year-end, and also ordered the exclusion of several functionally non-comparable companies from the benchmarking analysis – click here;
  • India: The Mumbai Income Tax Appellate Tribunal (ITAT) deleted a transfer pricing adjustment on interest paid on non-convertible debentures, holding that the transfer pricing officer could not apply an ad hoc 10-year maturity filter without demonstrating its economic relevance to the transaction – click here;
  • India: The Delhi Income Tax Appellate Tribunal (ITAT) rejected the application of a mechanical 50% turnover filter and held that transfer pricing adjustments should be restricted to international transactions with associated enterprises, while also allowing certain comparability adjustments – click here;

Webinars

  • Webinar: Seminars organized by NAFA in September 2026 – click here;

Romania

  • Romania: New rules for obtaining an advance individual tax ruling. The procedure has been published in the Official Gazette – click here;
  • Romania: Starting in 2027, transfer pricing adjustments will also come with incentives… for the NAFA team! – click here.
Note: Please note that TPS could not be held responsible for the content and accuracy of the information obtained by accessing these websites, nor for the consequences resulted from any activities one performs based on this information. Even though we are monitoring the outbound links, we do not have control over the availability of the information offered by external references or how often the information is updated.

Contacts

email: letstalk@transferpricing.global 

phone: 0040 742 159 142

 

Subscribe to our Newsletter





We value your privacy. Click here to find out more