With Order No. 13136 of 7 May 2026, the Italian Supreme Court issued an important ruling on transfer pricing and intra-group transactions. The Court held that a real guarantee granted by an Italian subsidiary in favour of a foreign parent company may fall outside the...
Taxes in Poland 2026 – A Report by ETL GLOBAL Member MDDP
Poland has long attracted foreign investors looking to establish and grow their business, remaining one of the leading investment destinations in Central and Eastern Europe. For any company considering the Polish market, tax is part of the investment decision from the...
Determination of “Arm’s Length” Interest Rates in the Republic of Serbia
The issue of determining the “arm’s length” interest rate in the Republic of Serbia is regulated by the Corporate Income Tax Law and the Transfer Pricing Rulebook. In this context, the Corporate Income Tax Law provides that, in addition to the standard methods, a...
Transfer Pricing in the Courts: Key International Trends You Shouldn’t Ignore
Transfer pricing is no longer shaped solely by guidelines and local regulations. Increasingly, court decisions across Europe are redefining how tax authorities interpret and challenge intra-group transactions. This is exactly why MDDP has prepared a comprehensive...
Tax and Accounting Considerations for Companies Operating in Ireland – A Guide by Noone Casey
Foreign companies entering the Irish market face a tax system where local compliance, cash flow timing, and profit extraction require early and informed decisions. ETL GLOBAL Member Noone Casey outlines the key tax and accounting matters affecting Irish operations,...
Transfer pricing in practice: Bulgaria vs. Macao (China) – Key Similarities and Differences for Multinational Groups
Transfer pricing regulations continue to evolve globally, with jurisdictions increasingly aligning with OECD standards while maintaining distinct local approaches to compliance and enforcement. This article provides a comparative overview of transfer pricing...
Hungary brings back the Advertising Tax
The advertising tax was first introduced into the Hungarian tax system in 2014. Following significant amendments adopted in 2017, its application was suspended in 2019. After the most recent legislative changes, the advertising tax will again apply as of 1 July 2026,...
TP Audits and Controversy: Focus Areas in Romania and Germany
Transfer pricing audits conducted by tax authorities are no longer regarded as a purely formal exercise. In recent years, authorities have developed an increasingly analytical approach, based on detailed financial testing and a strict interpretation of the arm’s...
Understanding Brazil’s New Consumption Tax Framework: A Guide by Numeric Brasil
Brazil is moving ahead with one of the most significant changes to its consumption tax system in recent decades. Through new constitutional and legislative measures, the country has begun replacing a fragmented structure of indirect taxes with a unified VAT-based...
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