brought to you by TPS
Europe
- EU: The Council updates the EU list of non-cooperative tax jurisdictions – click here;
- Netherlands: Supreme Court clarifies scope of reversal and increase of burden of proof – click here;
- San Marino: Advance tax rulings and advance pricing agreements (APAs) for cross-border transactions – click here;
- France: Certain proposed tax measures in 2027 Finance Bill adopted by Finance Committee, including change to Pillar Two threshold – click here;
- Guernsey: Tax Reform 2026 package approved – click here;
Global
- OECD: Tax report to G20 Finance Ministers addresses business dynamism – click here;
- Australia: Public CBC reporting lodgment deferral: entities with a public CBC reporting obligation due 31 December 2026 have a deferral to 29 January 2027 – click here;
- India: Protocol to income tax treaty with Mauritius enters into force, incorporates principal purpose test– click here;
- Kenya: Final regulations under Pillar Two law – click here;
- Hong Kong SAR: Substance-based Tax Incentive (SBTI) may mitigate the interaction between Pillar Two and the enhanced R&D tax deduction – click here;
- Global: CFE’s Tax Top 5 – 12 October 2026 – click here;
TP Cases
- Romania: CJEU. C-725/26 | Romagnetics. Preliminary reference on the adjustment of transfer prices to the median of the arm’s length range – click here;
- Romania: CJEU. C-740/26 | KMG Rompetrol Development. Preliminary reference on the solidarity contribution applied to related companies – click here;
Romania
- Romania: NAFA’s H1 2026 activity report: progress in transfer pricing risk analysis, but limited transparency on criteria and results – click here and here;
- Romania: NAFA Antifraud uncovers a fictitious invoicing scheme causing losses of over RON 6.2 million – click here;
- Romania: New NAFA procedure on joint liability: when a company’s tax debts can be transferred to its administrators, shareholders or other responsible persons – click here;
- Romania: Personal debts of the shareholder paid by the company: legal conditions, tax treatment and required documents– click here;
- Romania: Niculescu Cabinet’s governing programme: ~6% deficit target for 2026, 2027 budget by year-end and removal of the minimum turnover tax (IMCA) – click here;
- Romania: Transfer of shares in a limited liability company (LLC): mandatory 15-day notification to NAFA – click here;
- Romania: Chamber of Tax Advisors: companies risk penalties as no cash register can yet issue the required QR code – click here.
