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Transfer Pricing

Transfer Pricing

TaxNewsFlash-Transfer Pricing — KPMG's reports of transfer pricing developments from across the globe


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TaxNewsFlash-Transfer Pricing

Transfer Pricing Review (2015)

Transfer Pricing Review provides transfer pricing information for almost 100 countries, including documentation requirements, deadlines, transfer pricing methods, penalties, special considerations, advance pricing agreements, and competent authority matters.

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TaxNewsFlash-Transfer Pricing

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Prior Editions

Prior editions of TaxNewsFlash-Transfer Pricing (from 2014) are listed below, and are searchable by key words.

For a copy of a prior edition, send an email to with (1) date and (2) title. A copy will be sent to you as soon as possible.

2014 Editions [PDF 957 KB]

Recent articles

May 2018

11 May - United States: New IRS template for requesting advance pricing agreement (APA)

10 May - Taiwan: Country-by-country reporting for 2017 corporate income tax return

10 May - OECD: Comments requested on future revisions, Transfer Pricing Guidelines

1 May - Australia: ATO's final draft, Australian Local file requirements for 2018 tax years

April 2018

27 Apr - Hong Kong: Transfer pricing amendments to the “BEPS bill”

25 Apr - India: Arm’s length price of related party not controlling on taxpayer

19 Apr - Denmark: Transfer pricing documentation; court applies contemporaneous preparation rule

18 Apr - Poland: Transfer pricing forum considers benchmarking studies, simplified APA procedure

17 Apr - New Zealand: Effects of transfer pricing adjustments on post-import valuation, pending customs legislation

10 Apr - United States: Updated FAQs on country-by-country reporting, guidance for national security contractors

10 Apr - OECD: Transfer pricing “country profiles” add new profiles for 14 countries

5 Apr - Singapore: Cost plus mark-up basis of assessment for service companies

4 Apr - United States: Observations about Notice 2018-31: Country-by-country reporting by “specified national security contractors”

March 2018

30 Mar - United States: APMA program, APA statistics for 2017

30 Mar - United States: IRS guidance on country-by-country reporting by “specified national security contractors”

26 Mar - Argentina: Country-by-country notification deadline extended to 2 May 2018

26 Mar - India: APA authorities accept customs valuation as arm’s length price for transfer pricing purposes

23 Mar - UK: Voluntary preparation of Master file, Local file documentation; UK-parented multinational entities

22 Mar - OECD: Additional guidance on attribution of profits to permanent establishments (BEPS Action 7)

21 Mar - EU: Proposals for taxation of digital businesses

21 Mar - Spain: Retroactive transfer pricing adjustments, considerations for customs valuation purposes

20 Mar - Nigeria: Country-by-country reporting to be added to transfer pricing rules

19 Mar - Dominican Republic: Tax authorities requesting transfer pricing studies, verifying interest deductibility of related-party transactions

16 Mar - OECD: Interim report, tax challenges from digitalisation (BEPS)

16 Mar - Singapore: Discussion of revised transfer pricing guidelines

16 Mar - Poland: Extended deadline for transfer pricing documentation requirements

16 Mar - India: Lower house passes Finance Bill 2018; changes to country-by-country reporting, Master file rules

16 Mar - Serbia: Arm’s length interest rates “rulebook” for 2018; transfer pricing documentation implications

13 Mar - EU: Disclosure rules, reportable cross-border arrangements by tax advisers

12 Mar - OECD: Improving tax dispute resolution mechanisms under BEPS Action 14, including MAP access

7 Mar - EU: Aggressive tax planning; focus on interest, royalties, transfer pricing

6 Mar - Mauritius: Country-by-country reporting regulations, effective July 2018

6 Mar - Malaysia: Updated form for cross-border transactions, transfer pricing risk assessments

February 2018

28 Feb - Singapore: Expanded transfer pricing rules

27 Feb - India: APAs on treatment of advertising, marketing, and promotion expenses

26 Feb - Kazakhstan: Transfer pricing documentation includes country-by-country reporting

26 Feb - Lithuania: New transfer pricing documentation rules in draft order

23 Feb - UK: Updated MAP statement of practice and HMRC associated guidance

22 Feb - Italy: Draft transfer pricing regulations released for public consultation

13 Feb - Costa Rica: Details on country-by-country reporting requirements

13 Feb - Norway: Guidelines for mutual agreement procedure (MAP)

13 Feb - Poland: Guidance on preparation of transfer pricing documentation

9 Feb - Croatia: Determining the interest rate on related-party loans

8 Feb - OECD: Update on BEPS implementation, country-by-country reporting

6 Feb - Malaysia: Revisions, updates to APA rules and MAP guidelines

2 Feb - India: Transfer pricing proposals in 2018 budget, country-by-country reporting clarifications

January 2018

30 Jan - Jamaica: Transfer pricing declaration, file with income tax return

29 Jan - Australia: Country-by-country reports, Master and Local files due 15 February 2018, Australian taxpayers with December year-end

24 Jan - OECD: Multilateral risk assessment pilot program, transfer pricing information

23 Jan - Sweden: Timing of data, information to test benchmarking analysis for arm’s length pricing

22 Jan - Australia: ATO guideline on cross-border related-party financing arrangements, transactions

22 Jan - Belgium: Taxpayers can expect busy transfer pricing years ahead, following new three-layered approach applied by Belgian tax authorities

18 Jan - United States: Updated FAQs, information about country-by-country reporting

17 Jan - Brazil: Changes to “tax haven” and “privileged tax regimes” lists, implications for applying transfer pricing rules

16 Jan - United States: LB&I directives on transfer pricing examinations

16 Jan - Denmark: New deadlines for preparing, submitting transfer pricing documentation

9 Jan - Taiwan: Safe harbor exemption, Master file and country-by-country reporting submissions

8 Jan - India: First bilateral APA signed with United States

5 Jan - Thailand: Cabinet approves transfer pricing measures, with amendments

5 Jan - France: Transfer pricing documentation measures included in new law

5 Jan - Malaysia: Country-by-country reporting update

3 Jan - Argentina: Transfer pricing rules reformed, revised

3 Jan - EU: Retroactive transfer pricing adjustments and EU customs valuation

2 Jan - Hong Kong: BEPS legislation, move towards enhanced transfer pricing enforcement regime

December 2017

26 Dec - China: Guidance clarifying country-by-country reporting, information exchange

22 Dec - Austria: Country-by-country reporting by year-end

22 Dec - India: Aggregation of IT services provided to related parties, single composite contract

21 Dec - Switzerland: Country-by-country reporting for FY 2016, filing is due 31 December 2017

21 Dec - Malaysia: Reminder of approaching country-by-country reporting notification deadline

21 Dec - OECD: Jurisdictions implement final regulations for first filings of country-by-country reports

20 Dec - France: Country-by-country reporting; transitional measure announced by French tax authorities

18 Dec - Netherlands: EC state-aid investigations, whether tax rulings provide “unfair advantage”

18 Dec - Germany: Transfer pricing adjustments for non-arm’s length transactions with non-resident related companies, CJEU Advocate General’s opinion confirms

15 Dec - Hungary: Country-by-country reporting and notification requirements, deadlines

14 Dec - Czech Republic: Binding rulings, determining tax base of permanent establishments available in 2018

14 Dec - Czech Republic: Review of first-phase common errors, country-by-country reporting

13 Dec - Canada: Country-by-country reports due 31 December 2017

13 Dec - New Zealand: BEPS implementing legislation would affect related-party loans, transfer pricing rules

12 Dec - Italy: Deadline for filing country-by-country reports postponed

11 Dec - Greece: Guidelines for country-by-country reports

8 Dec - South Africa: Country-by-country reporting returns, due date extended

4 Dec - OECD: First review of BEPS Action 5 minimum standard, spontaneous exchange on tax rulings

1 Dec - Italy: Implementing guidelines for country-by-country reports

November 2017

30 Nov - OECD: Updated guidance on country-by-country reporting (BEPS Action 13)

28 Nov - Thailand: Update on transfer pricing proposals

27 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2016

23 Nov - Australia: ATO grants extension of time to file country-by-country statements

22 Nov - Taiwan: Transfer pricing documentation to include country-by-country reporting, Master file

21 Nov - Romania: Guidance on form for country-by-country reporting

21 Nov - United States: IRS update to jurisdiction status table, country-by-country reporting

20 Nov - Peru: Transfer pricing documentation—country-by-country reporting, Master file, Local file

17 Nov - UK: New corporate interest restriction rules intersect with transfer pricing

15 Nov - Canada: APA statistics for 2016

8 Nov - United States: IRS practice units on APAs for tangible goods transactions

8 Nov - WCO: Case study; transfer pricing documentation and customs valuation

7 Nov - Costa Rica: Country-by-country reporting, draft resolution released

6 Nov - OECD: Updated transfer pricing profiles from 31 countries

3 Nov - Hungary: Transfer pricing documentation requirements updated, including arm’s length pricing

3 Nov - Italy: Agreement for automatic exchange of country-by-country reports with United States

2 Nov - India: Final rules on country-by-country reporting, Master file requirements

1 Nov - Bulgaria: Country-by-country reporting procedure, format approved

October 2017

31 Oct - India: Unilateral APA addresses marketing, trading, and assembly activities

27 Oct - India: Unilateral APA with taxpayer in travel sector

26 Oct - India: First country-by-country report due date extended to 31 March 2018

25 Oct - OECD: Public consultation on 1 November, tax challenges of digitalisation

20 Oct - Hungary: Country-by-country reporting form, released by tax authority

20 Oct - OECD: Public consultations on transfer pricing matters

18 Oct - OECD: Comments to tax challenges of digitalization (BEPS Action 1)

18 Oct - Poland: Country-by-country reporting, template of electronic form available

13 Oct - Kosovo: Annual report (2016) of controlled transactions due 30 November

12 Oct - Finland: Guidance concerning intra-group services, determining arm’s length mark-up

11 Oct - Czech Republic: Country-by-country reporting implemented

11 Oct - OECD: Country-by-country reporting implementation status, exchange relationships (BEPS Action 13)

11 Oct - Poland: Decree on information to include in transfer pricing documentation

10 Oct - Greece: Country-by-country reporting update

9 Oct - India: Proposed country-by-country reporting, Master file rules

6 Oct - OECD: Comments on BEPS discussion drafts, attribution of profits to permanent establishments and transactional profit splits

5 Oct - Vietnam: Transfer pricing audits of related-party royalty, service fee payments

5 Oct - Luxembourg: Transfer pricing rulings granted multinational entity group; EC state aid investigation

5 Oct - Malaysia: Country-by-country reporting guidance

3 Oct - Switzerland: Country-by-country reporting ordinance effective 1 December 2017; voluntary reporting begins 1 November

2 Oct - KPMG report: Common-sense transfer pricing compliance in a BEPS world

September 2017

29 Sep - Japan: Tax agency’s Q&A guidance on mutual agreement procedure (MAP)

26 Sep - Argentina: Country-by-country reporting rules

21 Sep - EU: EC communication on taxation of single digital economy; alternative transfer pricing approaches being considered

20 Sep - United States: IRS updates country-by-country reporting guidance

20 Sep - OECD: IT guidelines for country-by-country reporting exchanges

19 Sep - KPMG report: Discussion draft, attribution of profits to permanent establishments (comments on BEPS Action 7)

18 Sep - KPMG report: Discussion draft, BEPS Action 10 revised guidance on profit splits

18 Sep - United States: LB&I practice units about transfer pricing issues

15 Sep - UK: Effects of diverted profits tax on transfer pricing adjustments; 90% increase

14 Sep - Lithuania: Country-by-country reporting rules

13 Sep - Spain: New form for reporting related-party transactions, or transactions involving “tax havens”

12 Sep - Ireland: Transfer pricing included in recommendations for corporation tax

6 Sep - OECD: New guidance on country-by-country reporting (BEPS Action 13)

5 Sep - Denmark: Annual reporting on transfer pricing adjustments

August 2017

30 Aug - United States: List of countries for country-by-country reporting data exchanges

30 Aug - Australia: Interaction between ATO and multinational companies; corporate tax avoidance inquiry includes focus on transfer pricing rules

29 Aug - Taiwan: Country-by-country reporting requirements in draft transfer pricing documentation rules

22 Aug - Country-by-country reporting: Timeline of notification requirements per country

22 Aug - Australia: Practical experiences on filing Part A of Australian Local files for some “significant global entities”

21 Aug - Australia: Taxpayer withdraws appeal; transfer prices and related-party loans

18 Aug - UK: Updated HMRC guidance for filing country-by-country reports

17 Aug - Bulgaria: Rules for country-by-country reporting

17 Aug - Greece: Country-by-country reporting measures are enacted

14 Aug - Latvia: Transfer pricing reporting requirements include country-by-country reports

11 Aug - United States: IRS now accepting country-by-country report (Form 8975)

7 Aug - Kosovo: Transfer pricing requirements, documentation rules

4 Aug - New Zealand: Update on BEPS, transfer pricing proposals

2 Aug - India: Foreign exchange fluctuation gain or loss, operating income and arm’s length pricing

1 Aug - Hong Kong: Transfer pricing legislation expected by late 2017; findings of BEPS consultation

1 Aug - India: Country-by-country reporting, update

1 Aug - OECD: Draft toolkit, addressing taxation of offshore indirect transfers of assets

July 2017

28 Jul - Asia Pacific: Transfer pricing review, third quarter 2017

28 Jul - India: “Location savings” not sole basis for arm’s length price

26 Jul - United States: Cancellation of APAs by IRS, abuse of discretion

20 Jul - Czech Republic: Legislation for implementing country-by-country reporting advances

19 Jul - Australia: ATO compliance activity relating to transfer pricing; updates about compliance, CbC documentation

18 Jul - OECD: Additional guidance for country-by-country reporting (BEPS Action 13)

13 Jul - Mexico: Negotiating APAs, “fast track” for maquila companies

13 Jul - Vietnam: Tax and transfer pricing implications of technology transfers, new law

12 Jul - Malaysia: Updated guidelines for transfer pricing

11 Jul - Singapore: Draft transfer pricing legislation

10 Jul - OECD: Updates to transfer pricing guidelines for multinational enterprises

10 Jul - Asia Pacific: Country-by-country reporting; implementation issues

7 Jul - EU: European Parliament adopts report on proposal for “public” country-by-country reporting

7 Jul - Asia Pacific: Survey of country-by-country reporting in 15 countries

7 Jul - United States: IRS provides FAQs on country-by-country reporting

5 Jul - OECD: Comments on BEPS discussion draft; guidance on hard-to-value intangibles

5 Jul - Japan: Retroactive transfer price adjustments, from customs valuation perspective

5 Jul - Nigeria: Overviews of transfer pricing regime, audit process

June 2017

30 Jun - United States: Form 8975 and instructions for country-by-country reporting; IRS launches CbC webpage

29 Jun - Thailand: Transfer pricing regime pending public comments, final steps

28 Jun - India: APA concerning severance pay to information technology-enabled service employees

27 Jun - KPMG report: Discussion draft, BEPS Action 10 revised guidance on profit splits

23 Jun - Italy: Transfer pricing rules are revised

23 Jun - Romania: Country-by-country reporting added to tax law

22 Jun - OECD: Toolkit for “developing countries” to address lack of comparables for transfer pricing analyses

22 Jun - OECD: BEPS inclusive framework, update on country-by-country reporting exchanges (including update for United States)

22 Jun - OECD: BEPS discussion drafts, attribution of profits to permanent establishments and transactional profit splits

21 Jun - Canada: New exchange arrangement with United States, to implement country-by-country reporting standard

21 Jun - EU: Proposed mandatory disclosure of reportable tax planning cross-border arrangements

20 Jun - India: Notional interest on “deemed advances” involving transfer pricing adjustments of related parties

19 Jun - India: Tribunal rejects internal comparables, but looks to comparability factors of location, value chain, product utility

19 Jun - UK: Country-by-country reporting, notification to HM Revenue & Customs

16 Jun - Russia: Status of country-by-country reporting, transfer pricing documentation proposals

12 Jun - Costa Rica: Time for filing transfer pricing returns is extended

9 Jun - India: Revised “safe harbour rules” focus on transfer pricing disputes

7 Jun - Azerbaijan: Transfer pricing rules introduced; effective for 2017

7 Jun - India: Evaluating advertising and marketing promotion expenses as international transaction

6 Jun - Colombia: Transfer pricing regime, rules for controlled foreign corporations

6 Jun - Hungary: Country-by-country reporting approved by parliament

May 2017

30 May - OECD: Initial impressions about discussion draft, hard-to-value intangibles

30 May - Pakistan: Transfer pricing audit, penalty provisions in budget 2017

30 May - Turkey: Transfer pricing provisions and country-by-country reporting rules

26 May - KPMG report: Potential ripple effects of BEPS reforms, beyond tax issues

25 May - India: Expense reimbursements not taxable; transfer pricing study showed no profit element

24 May - Israel: Update on status of country-by-country reporting

23 May - OECD: Discussion draft, guidance on hard-to-value intangibles

22 May - India: Excluding cost reimbursements from related parties (without mark-up) from operating costs

22 May - India: Export commission paid to related party not a royalty; transfer pricing adjustment rejected

18 May - Australia: Related-party financing arrangements, analysis

18 May - France: Country-by-country reporting notification and filing requirements

17 May - India: Brand development not separate international transaction, warranting transfer pricing adjustment

16 May - Australia: ATO draft guidance on related-party financing arrangements

16 May - Czech Republic: Update on transfer pricing assessments

11 May - Korea: Update on country-by-country reporting, transfer pricing rules

9 May - India: Convertible loans, loan guarantees for foreign related parties

9 May - Singapore: Cost-plus mark-up basis available for service companies, providing routine services to related parties

8 May - Norway: Proposed earnings stripping rule changes; interest paid to related parties

8 May - UK: Group ratio method and related parties, possible corporate
interest restriction

5 May - India: Report of APA statistics

4 May - OECD: Country-by-country reporting implementation status; exchange relationship between tax administrations


April 2017

27 Apr - United States: Government appeals Tax Court’s decision, section 482 adjustment

25 Apr - Costa Rica: Master file, Local file and other recordkeeping requirements

23 Apr - Russia: Updated country-by-country reporting, transfer pricing documentation proposals

21 Apr - Australia: Transfer pricing implications of related-party loans; appellate court decision

21 Apr - Netherlands: Measures on exchanging country-by-country reports

20 Apr - UN: Updated transfer pricing publication, developing countries

19 Apr - Australia: Country-by-country reporting, Local and Master files detailed design

14 Apr - Mexico: Final rules, annual information returns of related parties

13 Apr - Czech Republic: Proposed amendment requires multinational groups to prepare country-by-country report

10 Apr - UK: Transfer pricing dispute resolution, new remedies reflecting BEPS recommendations

6 Apr - OECD: Updated country-by-country guidance, under BEPS Action 13

5 Apr - Australia: Simplified transfer pricing record-keeping options

5 Apr - India: Transfer pricing adjustments for intra-group services

3 Apr - Germany: Discussion draft, transfer pricing documentation requirements

3 Apr - United States: Transfer pricing documentation deadlines for 2017

March 2017

30 Mar - China: Guidance integrating BEPS, transfer pricing audit practices

30 Mar - India: Five APAs signed, transactions involving management cross-charges

29 Mar - Poland: Transfer pricing, country-by-country reporting exchange of information

27 Mar - US: APMA program, APA statistics for 2016

15 Mar - India: Related-party relationship upheld, sales constituted 20% of total sales

15 Mar - Serbia: Arm’s length interest rates for related-party financing

14 Mar - Australia: Considering how CbC reporting may affect globally mobile workforce

14 Mar - India: Penalty assessment for related-party transactions deleted, even though taxpayer accepted transfer pricing adjustment

13 Mar - Australia: ATO guidance for the Australian “Local file”

10 Mar - Italy: Implementing decree, country-by-country reporting rules

8 Mar - Sweden: Guidance on country-by-country reporting notification, filing process

3 Mar - Sweden: Transfer pricing documentation, country-by-country reporting legislation passed by parliament

3 Mar - New Zealand: Transfer pricing, BEPS measures released for consultation

2 Mar - Cyprus: Back-to-back loans to require transfer pricing study

1 Mar - Vietnam: Country-by-country reporting part of expanded transfer pricing documentation guidelines

February 2017

28 Feb - Argentina: Court characterizes intercompany loan as capital contribution

28 Feb - India: Profits attributed to permanent establishment; transfer pricing study rejected

28 Feb - Poland: Significant increase in revenue collections, following transfer pricing audits

24 Feb - United States: Draft instructions for Form 8975, Country-by-Country Report

23 Feb - India: Resale price method, distributor adds no value to goods

23 Feb - South Africa: Transfer pricing measures in 2017 budget

22 Feb - Hong Kong: Transfer pricing in budget speech; proposed legislation expected

21 Feb - OECD: Comments on helping developing countries, lack of comparables for transfer pricing analyses

17 Feb - Canada: Country-by-country reporting form is released

14 Feb - France: Country-by-country reporting form

10 Feb - Botswana: Introduction of transfer pricing legislation under consideration

10 Feb - UK: HMRC guidance on transfer pricing aspects of cash pooling

9 Feb - Hong Kong: Update on introduction of transfer pricing rules

9 Feb - India: Update on APAs

3 Feb - India: Transfer pricing proposals in budget 2017

1 Feb - OECD: Peer review documents, assessment of BEPS minimum standards (Actions 13 and 5)

January 2017

27 Jan - UK: Revised HMRC guidance, no transfer pricing discussions outside APAs

26 Jan - Indonesia: New transfer pricing requirements include country-by-country reporting

25 Jan - OECD: Helping developing countries with comparables for transfer pricing analyses

24 Jan - Belgium: Transfer pricing documentation

24 Jan - Nigeria: Transfer pricing forms for 2017

20 Jan - Australia: ATO guidance on related-party marketing hubs

19 Jan - India: Loss-making companies as comparables

19 Jan - United States: IRS guidance on country-by-country report filing process

16 Jan - Australia: Q&As on country-by-country reporting

16 Jan - Singapore: Updated transfer pricing guidelines released

14 Jan - Peru: Transfer pricing legislation reflects OECD recommendations

12 Jan - United States: Draft Form 8975 for country-by-country reporting

11 Jan - Brazil: Certain Austrian holding companies identified as “privileged tax regime”

10 Jan - Cyprus: Decree adopting country-by-country reporting; notification extended to October 2017

6 Jan - Malaysia: Final rules on annual country-by-country reporting

5 Jan - Dominican Republic: Update of “white list” countries, transfer pricing implications

4 Jan - United States: IRS practice unit, section 367(d) transactions and cost sharing arrangments

3 Jan - Brazil: Country-by-country reporting rules

3 Jan - Chile: Country-by-country reporting required in new transfer pricing affidavit

3 Jan - Korea: Country-by-country reporting, transfer pricing reporting proposed changes

December 2016

29 Dec - Luxembourg: Revisions to transfer pricing circulars; intra-group financing transactions

28 Dec - Luxembourg: Country-by-country reporting, notification procedure

23 Dec - Ireland: EC state aid investigation of transfer pricing rulings

22 Dec - Dominican Republic: Transfer pricing compliance; free trade zone waivers

15 Dec - Slovakia: Country-by-country reporting introduced in new government bill

13 Dec - France: Country-by-country public financial reporting held unconstitutional

9 Dec - Denmark: Country-by-country notification requirements

7 Dec - Australia: Country-by-country reporting Q&As

5 Dec - Norway: Country-by-country reporting pursuant to BEPS Action 13

5 Dec - OECD: BEPS guidance on country-by-country reporting, country-specific information on implementation

5 Dec - OECD: Mutual agreement procedure (MAP) statistics for 2015

2 Dec - Belgium: Transfer pricing documentation forms are published

November 2016

30 Nov - Czech Republic: High court disallows loss for “toll manufacturer”

30 Nov - Finland: Country-by-country reporting, Master file, Local file requirements

28 Nov - Luxembourg: Pending draft law, implications for transfer pricing studies

23 Nov - France: Reduced threshold, eligibility for abridged transfer pricing documentation

22 Nov - U.S. Tax Court: Taxpayer entitled to full DRD, accounts receivable under section 965

22 Nov - Netherlands: Country-by-country reporting, 2016 notification deadline is extended

21 Nov - India: Transfer pricing method applies uniformly to all international transactions

18 Nov - India: Update on MAP, bilateral APA case resolution with United States

17 Nov - Brazil: Initial BEPS guidance on dispute resolution; CbC consultation

11 Nov - UK: Updated HMRC guidance on APAs

2 Nov - South Africa: Additional transfer pricing documentation rules are finalized

1 Nov - OECD: Taxpayer questionnaire, input into MAP process

October 2016

28 Oct - Hong Kong: Consultation on formal transfer pricing regime

28 Oct - OECD: Automatic exchange of tax information agreement, signed by Cook Islands

25 Oct - Channel Islands: Country-by-country reporting, draft regulations in Jersey

24 Oct - Singapore: Country-by-country reporting guide

21 Oct - Ireland: Irish Revenue updates FAQs on country-by-country reporting

21 Oct - OECD: Five jurisdictions agree to automatic exchange of country-by-country reports

21 Oct - Vietnam: Draft decree to implement transfer pricing standards, BEPS recommendations

20 Oct - Ireland: Transfer pricing considerations of centralised procurement strategies

18 Oct - China: New APA administrative guidelines, effective December 2016

18 Oct - India: Implications of APA on pre-rollback transactions

18 Oct - India: Transfer pricing implications of loan guarantee, working capital loans furnished related parties

18 Oct - India: Transfer pricing not applicable to transactions with foreign branch office

14 Oct - US: IRS position on unilateral APA applications involving maquiladoras

14 Oct - Luxembourg: Budget proposals, to transpose arm’s length principle, transfer pricing analysis

14 Oct - UK: Practical issues that businesses may face concerning country-by-country reporting

13 OctAustralia: Involving human resources, mobility professionals in country-by-country reporting 

11 Oct - India: Arm's length interest rate on related-party borrowings

11 Oct - India: Effects of customs duty, air freight, currency fluctuation adjustments on arm’s length price

10 OctFrance: Decree implementing country-by-country reporting

September 2016

28 Sep - Channel Islands: Country-by-country reporting, consultation in Guernsey

28 Sep - OECD: Public consultation on BEPS-related transfer pricing matters, 11-12 October

28 Sep - Sweden: Country-by-country reporting provisions in budget bill for 2017

27 Sep - Australia: Country-by-country reporting exemption guidance

23 Sep - United States: Guidance for IRS agents, applying arm’s length standard

20 Sep - India: Treaty with South Korea would allow bilateral APAs, MAPs

20 Sep - Denmark: New executive order on country-by-country reporting

16 Sep - Russia: Country-by-country reporting requirements, transfer pricing documentation

14 Sep - Costa Rica: Transfer pricing return, procedures are finalized

14 Sep - Pakistan: Automatic exchange of country-by-country reports

13 Sep - United States: EC state aid investigations show need for tax reform

9 Sep - UK: Public country-by-country reporting, amendment to Finance Bill 2016

7 Sep - OECD: Comments on BEPS discussion drafts—profit splits, profits attributed to permanent establishments

2 Sep - India: Effects of arm’s length price adjustment on taxable income

1 Sep - Brazil: Automatic exchange of country-by-country reports

August 2016

31 Aug - Germany: Transfer pricing rules requiring adjustment on cross-border arrangements referred to CJEU

31 Aug - Poland: Tax authorities continue to focus on transfer pricing

30 Aug - Ireland: EC state aid investigation, “illegal tax benefits” to multinational company of €13 billion

24 AugPoland: Cash-pooling arrangements are loans, transfer pricing documentation rules apply

24 AugPoland: Increased number of transfer pricing audits, increased assessments

24 AugOECD: Comments on proposed amendments, OECD Transfer Pricing Guidelines

22 Aug - Liechtenstein: Automatic exchanges of CRS, country-by-country reporting

19 AugAsia Pacific: Transfer pricing review (2016 supplement)

18 Aug Czech Republic: Automatic exchange of APAs, country-by-country reporting proposals

16 Aug India: Application of Berry ratio, transfer pricing methodology

16 Aug Israel: Country-by-country reporting, transfer pricing documentation in budget plan

16 Aug - Hong Kong: Management fee, head office recharge arrangements under scrutiny

16 Aug - Turkey: New transfer pricing rules enacted, aligned with OECD guidelines

15 Aug - Greece: Transfer pricing documentation deadline is extended

11 Aug - Nigeria: Country-by-country reporting, implementation moves forward

10 aug Australia: Amnesty for voluntary disclosure of offshore hub-related tax risks; transfer pricing implications

9 Aug - Canada: Discussion, observations about country-by-country reporting proposal

9 Aug - Germany: Loan guarantees by German parent company, for foreign subsidiaries

8 Aug - Asia Pacific: Country-by-country reporting, status update for region

8 Aug - EU: Country-by-country reporting—an EU perspective

5 Aug - Australia: Review of transfer pricing developments since 2012; plans for more changes

5 Aug - Luxembourg: Draft law for country-by-country reporting submitted to Parliament

5 Aug - India: No transfer pricing referral, when taxpayer claims no “international transactions”

5 Aug - India: Taxpayer allowed to change from TNMM to CUP during proceedings

3 Aug - Canada: Country-by-country reporting requirements in draft legislative proposals

1 Aug - Korea: Revised legislation, transfer pricing and country-by-country reporting rules

July 2016

29 Jul - Mexico: Transfer pricing measures in tax legislation

26 Jul - India: Transfer Pricing Officer’s authority to examine arm’s length price

25 Jul - Austria: New transfer pricing documentation, country-by-country rules effective for 2016

25 Jul - OECD: Report on status of BEPS project

21 Jul - Czech Republic: Regional courts reject basis for transfer pricing assessments

18 Jul - U.S. Tax Court: Newspaper’s motion to intervene in cost-sharing arrangement case held in abeyance

15 Jul - Hong Kong: Transfer pricing and offshore tax regimes

14 Jul - India: Taxpayer must have opportunity to cross-examine comparable companies’ personnel

13 Jul - China: Transfer pricing documentation, related-party reporting guidance from BEPS project

11 Jul - Hong Kong: BEPS participation, recommendations pending government action

8 Jul - India: Valuation of intangibles; only future projections, no hindsight allowed

7 Jul - OECD: Discussion draft under BEPS Actions 8-10, profit split guidance 

7 Jul - OECD: Discussion draft under BEPS Action 7, profits attributed to
permanent establishments

6 Jul - Hong Kong: Transfer pricing and BEPS considerations—intangible property and R&D activities

6 Jul - Sweden: Revising an agreement’s conditions to arm’s length terms

5 Jul - Belgium: Country-by-country reporting, transfer pricing documentation; new law is published

5 Jul - India: No transfer pricing adjustment; license agreement with U.S. company

4 Jul - Japan: Guidance under new transfer pricing documentation rules

4 Jul - OECD: BEPS discussion drafts include revised guidance on profit splits

4 Jul - OECD: Comments invited on revised transfer pricing guidelines

1 Jul - Germany: Country-by-country reporting, BEPS items in draft bill

OECD: Comments invited on revised transfer pricing guidelines

OECD: Comments invited on revised transfer pricing guidelines

OECD: Comments invited on revised transfer pricing guidelines

June 2016

29 Jun - United States: Initial description of country-by-country reporting final regulations 

29 Jun - OECD: Guidance on implementation of country-by-country reporting

29 Jun - United States: Country-by-country reporting, final regulations (text)

27 Jun - India: Prior MAP not justification for proposed transfer pricing adjustment

24 Jun - Singapore: Country-by-country reporting

22 Jun - India: No transfer pricing adjustment warranted for corporate guarantee

20 Jun - Finland: Transfer pricing documentation, country-by-country reporting draft legislation

17 Jun - India: Inconsistent positions of tax authorities; same transaction, different years

16 Jun - OECD: Webcast discussions about BEPS, tax transparency

15 Jun - OECD: BEPS amendments incorporated into Transfer Pricing Guidelines

13 Jun - Luxembourg: Tax ruling in EC state aid investigation is published

10 Jun - Costa Rica: Draft rules for annual transfer pricing return

9 Jun - US Tax Court: Medical devices and leads transfer pricing issues

3 Jun - UK: Proposed secondary adjustment rule, for transfer pricing provisions

May 2016

25 May - Australia: Country-by-country, final Local files released

25 May - Norway: Transfer pricing documentation, country-by-country reporting included in political agreement

23 May - US: Senators again express concerns about EC state-aid investigations

23 May - Denmark: Transfer pricing adjustment statistics, trends and

20 May - EU: “State aid” and transfer pricing rulings

19 May - Denmark: New transfer pricing documentation requirements

19 May - Austria: Proposed legislation, transfer pricing documentation and country-by-country reporting

16 May - Belgium: Draft law, country-by-country reporting and transfer pricing documentation requirements

13 May - Czech Republic: Transfer pricing examination trends

13 May - Norway: Proposed legislation to implement country-by-country reporting rules

12 May - OECD: Canada, Iceland, India, Israel, New Zealand, China advance country-by-country reporting

12 May - US: IRS practice unit, taxpayer’s affirmative use of section 482

11 May - Peru: New forms for transfer pricing declarations

10 May - Hungary: Transfer pricing measures in tax legislative proposals

10 May - India: No transfer pricing adjustment for advertising, marketing, and promotion

3 May - Sweden: Proposed legislation, transfer pricing documentation and
country-by-country reporting exchange

April 2016

28 Apr - India: APA for earlier year may apply, determining “tested party”

27 Apr - WCO: Agreement on transfer pricing, customs valuation

27 Apr - Japan: Country-by-country reporting requirements

26 Apr - Switzerland: Country-by-country reporting, implementing legislation advances

20 Apr - Canada: Procedures for exchange of tax rulings under BEPS rules

20 Apr - Bermuda: Country-by-country reports, automatic exchange agreement signed

14 Apr - India: Benchmarking the arm’s length interest rate on related-party debt

13 Apr - Canada: No cost-based transfer price reduction, government assistance

12 Apr - South Africa: Draft regulations, country-by-country reporting

12 Apr - EU: “Public” country-by-country reporting for multinational enterprises advances

11 Apr - India: Factors to be used in selecting comparables 

6 Apr - US: IRS practice unit examines three requirements to apply section 482

4 Apr - Canada: Country-by-country reporting in 2016  

1 Apr - Italy: New guidelines for international tax rulings and APAs

March 2016

31 Mar - US: APMA program, APA statistics for 2015

31 Mar - Korea: Master file and local file templates are released

28 Mar - UK: BEPS items included Finance (No. 2) Bill 2016 

24 Mar - OECD: Treaty benefits for non-CIV funds; BEPS follow-up consultation 

23 Mar - Canada: Country-by-country reporting, transfer pricing proposals in 2016 federal budget

23 Mar - EU: Draft proposal on “public” country-by-country reporting

22 Mar - India: No aggregation of transactions for benchmarking in “unusual” circumstances

22 Mar - OECD: Standardized electronic format for exchanging country-by-country reports

21 Mar - US: IRS “practice unit” on inbound resale price method, routine distributor

18 Mar - Turkey: Draft communiqué on transfer pricing documentation, country-by-country reporting

16 Mar - Indonesia: FAQs on transfer pricing

14 Mar - India: New guidelines for transfer pricing referrals

14 Mar - US: IRS “practice unit” on interest expense limitation under section 163(j), related-party debt

11 Mar - UK: Preparing for country-by-country reporting

10 Mar - Nigeria: Transfer pricing comparable data constraint—issues, implications

9 Mar - Australia: Costs of non-compliance with country-by-country reporting requirements

8 Mar - EU: Automatic exchange of country-by-country reporting by multinational companies

Mar 8 - India: Brand-promotion expenses not “international transaction” for arm’s length standard

7 Mar - US: Treasury responds to Congress, EU state-aid “tax ruling” investigations

7 Mar - US: IRS "practice unit," residual profit split method, outbound

4 Mar - Poland: Enhanced tax audit focus on transfer pricing

4 Mar - US: IRS “practice unit,” transfer pricing documentation by outbound taxpayers

3 Mar - UK: Final country-by-country reporting regulations

3 Mar - EU: State-aid investigations of “tax rulings,” response to U.S. concerns

2 Mar - Dominican Republic: Amount triggering transfer pricing regime, related-party transactions (2016) 

1 Mar - India: Country-by-country reporting, transfer pricing documentation rules in budget 2016

February 2016

29 Feb - US: Transfer pricing adjustments involving consolidated group members

22 Feb - India: Functional comparability of taxpayer’s business segments

22 Feb - New Zealand: Exchange of transfer pricing rulings

17 Feb - EU: Double taxation, dispute resolution mechanisms consultation 

16 Feb - India: Payment of 2% on sales considered at arm’s length

16 Feb - India: Valuing imports from a related party for customs purposes 

16 Feb - Romania: New rules, standards for transfer pricing documentation

12 Feb - Belgium: New wave of transfer pricing audits

11 Feb - US: Treasury letter to EC on state aid investigations 

11 Feb - Australia: Consultation on BEPS-related transfer pricing recommendations

4 Feb - South Africa: Mandatory transfer pricing documentation is proposed

4 Feb - US: IRS “practice unit” guidance on intercompany interest rates, cost sharing arrangements

3 Feb - Singapore: GST implications of transfer pricing adjustments

2 Feb - Nigeria: Country-by-country reporting update

1 Feb - US: Bilateral APAs with India being accepted, beginning 16 February

1 Feb - India: Bilateral APAs with UK, concerning management charges, brand royalty

January 2016

27 Jan - India: Cross-border share reorganisation, transfer pricing rules not triggered

27 Jan - OECD: Agreement signed for exchange of country-by-country reporting information

26 Jan - OECD: Countries to sign country-by-country implementation agreement

25 Jan - Singapore: New, updated transfer pricing guidance

20 Jan - France: Country-by-country reporting, transfer pricing declaration

15 Jan - Brazil: Revised position of tax authorities, cost-reimbursement arrangements

15 Jan - US: Senate Finance members urge Treasury intensify efforts, EU state aid investigations

13 Jan - Australia: Prepare now for country-by-country reporting

13 Jan - BEPS update: Countries implementing transfer pricing documentation, country-by-country reporting (table)

12 Jan - Finland: Transfer pricing documentation rules, country-by-country reporting proposal

6 Jan - Brazil: Dutch holding companies again identified as “privileged tax regimes”

6 Jan - Argentina: “White list” countries for 2016; transfer pricing implications

5 Jan - Norway: Country-by-country reporting proposal, public consultation

5 Jan - Netherlands: New transfer pricing documentation rules enacted; country-by-country reporting

4 Jan - Korea: Master file and local file; “full” transfer pricing reporting

2015 Articles

December 2015

29 Dec - Croatia: Related-party loans, interest rate increase for 2016

29 Dec - Poland: Ministry of Finance focus on transfer pricing 

23 Dec - US: KPMG report, proposed regulations on country-by-country reporting

23 Dec - Italy: Country-by-country reporting approved in 2016 budget law

22 Dec - Denmark: Country-by-country reporting for 2016

22 Dec - Ireland: Country-by-country legislation is enacted

21 Dec - US proposed country-by-country reporting regulations

18 Dec - Australia: Country-by-country reporting guidelines

17 Dec - India: Marketing intangibles by licensed manufacturer, no transfer pricing adjustment

15 Dec - Jamaica: Transfer pricing rules require reporting of related-party transactions (2015)

15 Dec - Japan: Transfer pricing documentation rules, based on BEPS recommendations

14 Dec - India: Corporate guarantee made for subsidiary, transfer pricing adjustment rejected

14 Dec - Mexico: Reminder of expanded transfer pricing disclosures for 2016

11 Dec - Korea: Agreement with India, suspending tax collection during pending MAP

8 Dec - EU: Directive on automatic exchange of tax rulings, APAs

3 Dec - Luxembourg: EC investigation of tax rulings, issued to US multinational

November 2015

30 Nov - Netherlands: Dutch government appeals EC decision, concerning APA

25 Nov - KPMG's Transfer Pricing Review (2015)

18 Nov - Nigeria: Implications of BEPS proposals

16 Nov - Netherlands: Advance tax rulings; changes possible before April 2016

11 Nov - India: No transfer pricing adjustment when tax avoidance not possible

10 Nov - UK: Changes to interest deductibility rules, implications for transfer pricing

9 Nov - France: Status of transfer pricing documentation, country-by-country reporting

5 Nov - Australia: Are investment entities excluded from “group” for country-by-country reporting?

5 Nov - Poland: Expanded transfer pricing, country-by-country reporting enacted

5 Nov - US: IRS practice unit, licensing of intangible property to foreign subsidiary

October 2015

29 Oct - India: No “notional interest” on related-party outstanding receivables

27 Oct - Australia: Transfer pricing, intercompany financing transactions

26 Oct - France: Recent trends in transfer pricing, survey

26 Oct - Hungary: Implementing transfer pricing-related BEPS actions

26 Oct - Singapore: Transfer pricing documentation, due 30 November

21 Oct - India: Transfer pricing guidance, case selection and multiple-year range

21 Oct - EU: “Tax rulings” in Luxembourg, Netherlands deemed illegal state aid

19 Oct - India: Valuation issues, fixed assets and cost sharing arrangement

13 Oct - OECD: Status of BEPS Action 13 local implementation, transfer pricing

9 Oct - Australia: BEPS and transfer pricing; comparison to Australian approach

6 Oct - EU: Automatic exchange of information, cross-border tax rulings and APAs

2 Oct - India: Comparables rejected; no add-back of transfer pricing adjustment

September 2015

24 Sep - Italy: Five-year tax agreement; treatment of cross-border items, transfer pricing

23 Sep - Denmark: Country-by-country reporting, documentation proposed

22 Sep - Korea: Related-party marketing fees not subject to customs duty

18 Sep - China: Transfer pricing discussion draft; BEPS influence

18 Sep - Mexico: Transfer pricing, country-by-country reporting proposals

17 Sep - Poland: Update on transfer pricing legislation

16 Sep - Netherlands: “Country-by-country” reporting, documentation proposed for 2016

16 Sep - Australia: Country-by-country bill introduced

15 Sep - Australia: Transfer pricing, changing nature of tax controversy

15 Sep - US: Regulations coordinating rules under sections 367, 482

14 Sep - France: Transfer pricing assessments; withholding tax relief for repatriated profits

8 Sep - India: No related-party relationship, despite substantial single-party purchases

8 Sep - India: Profit split method upheld, activities were “inextricably linked”

3 Sep - Nigeria: Safe harbour in the transfer pricing regulations?

August 2015

30 Aug - India: Voice-call centers; not all IT-enabled services are comparable

28 Aug - US: IRS training guides on foreign-to-foreign transactions, transfer pricing rules

26 Aug - Ecuador: Percentages for deducting royalties, other payments to related parties

20 Aug - Korea: Law to implement BEPS-related transfer pricing requirements

18 Aug - US: Explanation of competent authority revenue procedure

18 Aug - US: Explanation of new APA guidance

12 Aug - Australia: Country-by-country reporting update

12 Aug - US: New guidance for Competent Authority assistance

12 Aug - US: New guidance under APA program

10 Aug - Australia: Renewed focus on arm’s length behaviours

10 Aug - China: Cross-border payments to foreign related parties

7 Aug - Australia: Proposed CbC, transfer pricing documentation requirements

7 Aug - US: Future cost-sharing regulations, controlled transactions involving partnerships

6 Aug - India: First APA rollback signed; concerns U.S. company


July 2015

31 Jul - Hong Kong: Focus on head office, service company recharges

27 Jul - US: Tax Court finds cost-sharing regulations invalid

20 Jul - India: Interest on funds advanced to related entity

17 Jul - India: MAP with Japan; manufacturer’s transfer pricing resolved

15 Jul - India: Multiple-year data allowed, transfer pricing rules satisfied

8 Jul - Poland: Draft transfer pricing regulations, documentation and reporting requirements

7 Jul - China: Guidance on cost sharing agreements


June 2015

30 Jun - India: Comparables must be functional similar, not identical

30 Jun - India: “Groundbreaking” APA, taxpayer in IT industry

26 Jun - WCO: Guide on customs valuation, transfer pricing

22 Jun - Czech Republic: Next wave of transfer pricing inspections

22 Jun - India: No adjustment on share capital issuance

19 Jun - OECD: Comments, BEPS Action 8 (hard-to-value intangibles) discussion draft

13 Jun - India: APA rollback FAQs

12 Jun - Australia: Arm’s length, thin cap testing; transfer pricing landscape

12 Jun - OECD: Webcast provides BEPS status update

10 Jun - OECD: Initial impressions of BEPS country-by-country reporting implementation package

9 Jun - EU: Specific tax rulings requested from countries

8 Jun - Korea: Transfer pricing, customs valuations advance arrangements

8 Jun - OECD: Implementation package for BEPS country-by-country reporting

5 Jun - OECD: Initial impressions, BEPS Action 8 (hard-to-value intangibles)

5 Jun - Panama: Transfer pricing report deadline

5 Jun - India: Common director, management gives rise to “associated enterprises”

4 Jun - OECD: BEPS discussion draft, Action 8 (hard-to-value intangibles)

1 Jun - OECD: Comments on BEPS Action 8 (cost contribution arrangements)

1 Jun - Denmark: Enhanced transfter pricing reporting requirements, controlled transactions


May 2015

28 May - Sweden: Transfer pricing case pending high court decision 

27 May - Poland: Proposals to revise transfer pricing documentation rules

26 May - India: Draft rules on “range concept,” multiple-year data

26 May - Turkey: APA update

18 May - Korea: Simplified APA program for foreign SMEs

13 May - Australia: Transfer pricing-related measures in federal budget 2015

12 May - Jamaica: Transfer pricing legislation tabled

11 May - Thailand: Draft transfer pricing legislation

6 May - Indonesia: APA guidelines

5 May - India: Most appropriate method, under cost contribution agreement

5 May - OECD: Discussion of BEPS Action 8 (cost contribution arrangements)


April 2015

30 Apr - Italy: Pending transfer pricing, international tax reform proposals

30 Apr - India: Factors for including, excluding comparables

29 Apr - OCED: Discussion draft, BEPS Action 8 (cost contribution arrangements)

29 Apr - Turkey: APA draft guidance

28 Apr - Korea: Related-party marketing fee subject to customs duty

27 Apr - OECD: BEPS Action 11 (improving analysis of BEPS)

15 Apr - Norway: Tax authorities may use "secret comparables"

6 Apr - India: Interest rate on related-party loans

6 Apr - France: Intergroup arrangements identified in tax-avoidance transactions

6 Apr - US: Related-party indebtedness section 965 repatriation rules


March 2015

31 Mar - Spain: Enhanced documentation, reporting proposed; following BEPS Action 13

31 Mar - India: APA rollback application deadline is extended

30 Mar - US: APMA program statistics for 2014

24 Mar - Denmark: Transfer pricing adjustment trends, forecast

23 Mar - EU: Risks of investigations into tax rulings

23 Mar - Taiwan: Amendments to transfer pricing rules

19 Mar - India: Promotion expenses subject to transfer pricing rules

19 Mar - EU: Automatic exchange of cross-border tax rulings

17 Mar - India: APA rollback rules, pre-filing consultations

17 Mar - US: Accounts receivable not creating related-party indebtedness

2 Mar - Australia: Guidance for invoking reconstruction provisions

2 Mar - Serbia: Arm’s length interest rates, related-party loans

2 Mar - Vietnam: Reporting related-party transactions, arm’s length compliance


February 2015

27 Feb - Australia: Initial steps for APA process

25 Feb - Canada: Intercompany management fees

23 Feb - Italy: Aligning customs valuation, transfer pricing policy

20 Feb - Iceland: Transfer pricing regulations

19 Feb - OECD: Consultation on transfer pricing, 19-20 March

17 Feb - Australia: Transfer pricing recordkeeping rules

17 Feb - Ukraine: Transfer pricing rules are revised, expanded

12 Feb - OECD: Transfer pricing documentation, country-by-country reporting

11 Feb - Taiwan: Separate analysis for certain controlled transactions

10 Feb - OECD: BEPS comments, transfer pricing guidelines

10 Feb - India: Transfer pricing documentation for certain electric companies

9 Feb - Switzerland: Transfer pricing implications of exchange rate movements

6 Feb - OECD: Update on BEPS country-by-country reporting

5 Feb - New Zealand: Effects of Australian rules on trans-Tasman operations

5 Feb - Indonesia: Mutual agreement procedures (MAP) guidance

3 Feb - Belgium: New wave of transfer pricing audits

3 Feb - South Africa: Withholding tax on transfer pricing adjustments

2 Feb - India: No government appeals in equity infusion cases


January 2015

29 Jan - Spain: Law modifying related-party transactions

27 Jan - Switzerland: "Big data" approach to transfer pricing

27 Jan - India: Resolving MAP IT-related cases with United States

21 Jan - India: Functional, asset and risk analysis

21 Jan - France: Transfer pricing measures are enacted

20 Jan - OECD: Comments concerning BEPS Action 10 (low value-adding services)

19 Jan - OECD: Comments concerning BEPS Action 14 (dispute resolution)

19 Jan - Australia: Arm's length consideration and related-party loans

16 Jan - EU: Investigation of Luxembourg transfer pricing rulings

13 Jan - Greece: APA procedures, process

12 Jan - Bolivia: Transfer pricing requirements

12 Jan - OECD: Comments on BEPS Actions 6 and 7

7 Jan - Singapore: New transfer pricing guidelines

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