Recent Articles
August 2022
12 Aug - Australia: Proposal for increased public reporting of tax and country-by-country information
12 Aug - Malaysia: Effective tax rate; country-by-country reporting data used for transfer pricing purposes
10 Aug - Italy: Tax audits based on cross-border transactions, transfer pricing issues
10 Aug - Korea: Tax reform proposals include transfer pricing documentation and Pillar Two measures
9 Aug - Philippines: Guidance for taxpayers seeking MAP assistance
5 Aug - Australia: Consultation paper, multinational tax integrity and tax transparency
July 2022
29 Jul - Lithuania: Changes to APA rules
26 Jul - KPMG report: Amount B—the forgotten piece of the Pillar One jigsaw
22 Jul - Ireland: BEPS 2.0 implications for aviation sector
20 Jul - UK: Draft legislation to implement Pillar Two published
18 Jul - KPMG report: The diverging paths of Pillars One and Two
18 Jul - Czech Republic: Tax priorities of the Czech EU Presidency
14 Jul - EU: Update on minimum tax directive; priority of new presidency of the European Council
12 Jul - Netherlands: New decree on profit attribution to permanent establishments
11 Jul - OECD: Progress report on Amount A of Pillar One, including revised schedule; public consultation
11 Jul - Cyprus: Transfer pricing documentation legislation
11 Jul - Saudi Arabia: Proposed amendments to transfer pricing bylaws; comments due 30 July 2022
7 Jul - Netherlands: Details about changes in new transfer pricing decree
5 Jul - Poland: Transfer pricing measures in proposed legislation
1 Jul - Netherlands: New transfer pricing decree
1 Jul - KPMG report: Environmental, social, and governance (ESG) and transfer pricing
June 2022
29 Jun - Australia: Proposed amendments to thin capitalisation rules, effect on arm's length debt test
28 Jun - Malta: Update on transfer pricing landscape
27 Jun - UK: Background and implications of delayed implementation of Pillar Two
21 Jun - France: Multinational entity agrees to pay over €1.245 billion to resolve cross-border controversy
17 Jun - EU: Proposal for EU minimum tax directive; update after ECOFIN Council meeting
17 Jun - India: Updated guidance for mutual agreement procedure (MAP)
16 Jun - United States: Transfer pricing settlement initiative program for corporate taxpayers (New Jersey)
15 Jun - OECD: Comments on tax certainty aspects of Amount A under Pillar One
14 Jun - UK: Implementation of Pillar Two delayed
14 Jun - OECD: Tax transparency in Africa 2022
10 Jun - KPMG report: Comments on tax certainty aspects of Amount A under Pillar One
10 Jun - Luxembourg: Transfer pricing implications of new income tax treaty with UK
9 Jun - OECD: New transfer pricing country profiles for Egypt, Liberia, Saudi Arabia, and Sri Lanka
8 Jun - Peru: Approaching deadline for transfer pricing reports for FY 2021
7 Jun - KPMG report: Country-by-country reporting notifications, requirements per country
7 Jun - United States: Future of consumer and retail—transfer pricing perspective
6 Jun - Poland: Finance Minister’s reply to parliamentary inquiry regarding transfer pricing information
1 Jun - United States: Comments submitted to IRS regarding plans to update MAP and APA guidelines
May 2022
27 May - OECD: Tax certainty aspects of Amount A under Pillar One; public consultation
25 May - OECD: Comments on regulated financial services exclusion under Amount A of Pillar One
25 May - Hong Kong: Update on corporate tax issues, including transfer pricing documentation
24 May - EU: Status regarding proposal for EU minimum tax directive
20 May - KPMG report: Comments on regulated financial services exclusion under Amount A of Pillar One
20 May - China: Shenzhen launches first tax and customs collaborative transfer pricing management mechanism
16 May - KPMG report: Public consultation meeting on implementation framework of global minimum tax
9 May - Switzerland: Transfer pricing controversy statistics, including effects of COVID-19
6 May - Netherlands: Considerations for companies in scope of Pillar Two rules
6 May - New Zealand: Consultation on implementation of Pillar Two rules
6 May - OECD: Regulated financial services exclusion under Amount A of Pillar One; public consultation
5 May - KPMG report: BEPS 2.0 implementation considerations for Mexico
4 May - Nigeria: Summary of tax transparency reporting developments
4 May - OECD: Tax transparency in Latin America 2022
4 May - Poland: Transfer pricing reporting changes
3 May - OECD: Comments on extractives exclusion under Amount A of Pillar One
3 May - KPMG report: Comments on extractives exclusion under Amount A of Pillar One
3 May - KPMG report: Transfer pricing planning 2.0
3 May - KPMG report: Why operationalizing transfer pricing is more important than ever
3 May - Switzerland: Tax transparency reporting statistics and global minimum tax update
April 2022
28 Apr - KPMG report: Transfer pricing and the audit committee agenda, implementation steps
22 Apr - OECD: Comments on draft rules for domestic legislation on scope under Amount A of Pillar One
21 Apr - Kenya: Transfer pricing and other tax-related measures in Finance Bill, 2022
20 Apr - KPMG report: Comments on draft rules for domestic legislation on scope under Amount A of Pillar One
20 Apr - KPMG report: Transfer pricing and the audit committee agenda
20 Apr - Mexico: Considerations for maquiladora transfer pricing strategy, given elimination of APAs
20 Apr - Zimbabwe: Extended deadlines for corporate income tax and transfer pricing returns for 2021
14 Apr - KPMG report: Comments on implementation framework of global minimum tax
14 Apr - KPMG report: Comments in response to UK consultation on global minimum corporate tax
14 Apr - OECD: Comments on implementation framework of global minimum tax
14 Apr - OECD: Extractives exclusion under Amount A of Pillar One; public consultation
12 Apr - Brazil: Update on revisions to transfer pricing rules, steps toward OECD Transfer Pricing Guidelines
12 Apr - Zambia: Country-by-country reporting rules for 2021 tax year
11 Apr - Australia: Tax and transfer pricing implications of IBOR reform
11 Apr - Kenya: Proposed reporting requirements for multinational entities
11 Apr - Latvia: Implications of EU “public” country-by-country reporting for Latvian groups
5 Apr - EU: No agreement on revised proposal for minimum tax directive (ECOFIN Council meeting 5 April 2022)
4 Apr - OECD: Draft rules for domestic legislation on scope under Amount A of Pillar One; comments requested
1 Apr - Thailand: Extended deadline for filing transfer pricing disclosure form for 2020 (COVID-19)
March 2022
30 Mar - United States: APMA program, APA statistics for 2021 (IRS Announcement 2022-7)
28 Mar - Angola: Transfer pricing implications of updated list of “large taxpayers”
25 Mar - Canada: Mutual agreement procedure (MAP) statistics for 2020
23 Mar - Mexico: Changes introduced by new transfer pricing regulations
22 Mar - Thailand: Determining related parties when same group of shareholders involved
16 Mar - EU: ECOFIN fails to reach agreement on revised minimum tax directive
14 Mar - OECD: Commentary on Pillar Two model rules for domestic implementation of 15% global minimum tax
8 Mar - OECD: Comments on draft model rules for tax base determinations under Pillar One Amount A
4 Mar - KPMG report: Comments on OECD’s draft rules for tax base determinations under Pillar One
Amount A
3 Mar - Estonia: Amendments to transfer pricing regulation
2 Mar - KPMG report: BEPS 2.0 issues and implications for Latin America
1 Mar - Bulgaria: Withholding tax on “fictitious interest” assessed on interest-free loan (CJEU judgment)
February 2022
28 Feb - Belgium: Tax authorities launch annual round of transfer pricing audits
28 Feb - OECD: Third batch of 2021/2022 updated transfer pricing country profiles
28 Feb - KPMG report: Top concerns for tax leaders on the path forward for BEPS 2.0
28 Feb - Poland: Transfer pricing documentation and financial transactions involving loans
22 Feb - OECD: Comments on draft model rules for nexus and revenue sourcing under Pillar One Amount A
22 Feb - KPMG report: Operational transfer pricing health check
22 Feb - Thailand: Additional country-by-country reporting submission requirements
18 Feb - KPMG report: Initial impressions of draft rules for tax base determinations under Pillar One
Amount A
18 Feb - OECD: Draft rules for tax base determinations under Amount A of Pillar One; comments requested
17 Feb - KPMG report: Benefits of shared service centers in tax processes such as transfer pricing
17 Feb - South Africa: Draft interpretation note on intragroup loans, new transfer pricing guidance
16 Feb - Denmark: Updated guidance on transfer pricing documentation
15 Feb - Australia: Managing cross-border intercompany financing arrangements (court case)
15 Feb - Botswana: Review of transfer pricing rules
15 Feb - Italy: Guidance concerning transfer pricing documentation, penalty protection regime
11 Feb - Barbados: Rules requiring country-by-country reporting enacted
8 Feb - KPMG report: Transfer pricing in a deals context; risks and opportunities for value creation
7 Feb - Czech Republic: Economic challenges potentially affecting transfer pricing
7 Feb - UAE: Transfer pricing implications with introduction of a corporate income tax regime
January 2022
31 Jan - Mexico: APAs no longer available for maquiladora companies
28 Jan - KPMG report: Transfer pricing documentation viewed as ongoing process, not a short-term project
27 Jan - Cyprus: FAQs on intra-group back-to-back financing transactions
25 Jan - India: A decade of the APA program; why it still makes sense
21 Jan - KPMG report: Implicit guarantees in transfer pricing
20 Jan - Montenegro: New transfer pricing rules
20 Jan - OECD: Transfer pricing guidelines for multinational enterprises and tax administrations
18 Jan - Poland: Individual ruling is not equal to APA (court decision)
14 Jan - Croatia: Corporate profit tax interest rate on loans between related parties
13 Jan - Bahrain: Country-by-country obligations extended to 28 February 2022
12 Jan - Thailand: Extended deadlines for submitting country-by-country reports
11 Jan - UK: Public consultation on implementation of Pillar Two
11 Jan - Azerbaijan: Transfer pricing measures
7 Jan - KPMG report: Common transfer pricing risks and opportunities of M&A transactions
5 Jan - Nigeria: Country-by-country reporting requirements by branches and subsidiaries of foreign MNEs
4 Jan - Malta: Draft transfer pricing rules issued for public consultation
3 Jan - Poland: Safe harbor rate of interest, related-party loans in 2022
2021 Articles
December 2021
22 Dec - EU: Directive to implement Pillar Two is proposed
22 Dec - Cyprus: Country-by-country report for 2020 is due 31 January 2022
21 Dec - OECD: Schedule for public consultations on two-pillar solution
20 Dec - OECD: Pillar Two model rules for domestic implementation of 15% global minimum tax
17 Dec - KPMG report: Uneven transfer pricing implications of COVID-19 pandemic
15 Dec - Australia: Corporate tax transparency data for 2019-2020
14 Dec - KPMG report: Building an effective transfer pricing risk control framework
13 Dec - OECD: New and updated transfer pricing country profiles
10 Dec - Hungary: Considerations for year-end transfer pricing adjustments
2 Dec - Portugal: Guidance concerning advance pricing agreements, transfer pricing documentation
2 Dec - UK: Update on proposed changes regarding transfer pricing documentation
1 Dec - Bahrain: Country-by-country notifications due 31 December 2021
1 Dec - Zambia: Transfer pricing measures included in 2022 budget
1 Dec - EU: “Public” country-by-country reporting directive published in EU Official Journal
November 2021
30 Nov - Denmark: Changes to transfer pricing documentation requirements
30 Nov - Germany: Arm's length interest on intercompany loans (court decisions)
29 Nov - KPMG report: EU “public” country-by-country reporting and implications for multinational groups
26 Nov - Australia: Transfer pricing and ATO report on “reportable tax position” schedule
26 Nov - KPMG report: Automating transfer pricing documentation
22 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2020
22 Nov - UK: Transfer pricing items in HMRC annual report and accounts, 2020 to 2021
18 Nov - Australia: Deferral of date for filing (lodging) country-by-country reporting statements
18 Nov - KPMG report: Transfer pricing and factoring
16 Nov - Switzerland: Considerations for transfer pricing year-end adjustments
12 Nov - Netherlands: Legislation addressing mismatches in application of arm’s length principle
11 Nov - EU: European Parliament formally adopts “public” country-by-country reporting
8 Nov - KPMG report: Managing multilateral controversy
3 Nov - Poland: Transfer pricing measures in “Polish Deal” legislation
2 Nov - Dominican Republic: Transfer pricing rules, updated compliance and documentation requirements
2 Nov - United States: Voluntary transfer pricing initiative in Louisiana
1 Nov - China: APA annual report provides statistics for 2020
October 2021
22 Oct - Ireland: Transfer pricing measures included in Finance Bill 2021
20 Oct - Bahrain: Updated guidance on mutual agreement procedures
20 Oct - Thailand: Transfer pricing requirements and country-by-country reporting, effective 2021
18 Oct - Cyprus: Arrangement with United States for exchange of country-by-country reports
14 Oct - Austria: Transfer pricing guidelines 2021 are finalized
14 Oct - Serbia: Updated transfer pricing guidance, information for country-by-country report
14 Oct - Vietnam: Guidelines on APA program changes
13 Oct - OECD: G20 finance leaders endorse changes to global tax rules
13 Oct - Czech Republic: Arm’s length price, advertising as a deductible expense (court decision)
9 Oct - KPMG report: OECD/G20 Inclusive Framework agreement on BEPS 2.0
8 Oct - OECD: Agreement for global minimum tax, to resolve international taxation of digital economy
7 Oct - Thailand: New requirements for transfer pricing and Local file documentation
4 Oct - KPMG report: Country-by-country reporting, notification requirements per country
September 2021
29 Sep - Jordan: Instructions for implementing transfer pricing regime include documentation requirements
29 Sep - KPMG report: Managing transfer pricing and customs risks of cross-border transactions
28 Sep - EU: Update on "public" country-by-country reporting
27 Sep - Switzerland: Arm’s length price and transfer pricing implications of financial guarantees
22 Sep - Netherlands: Proposal to address mismatches in non-arm’s length transfer pricing
20 Sep - Poland: “Executed tax strategy” reporting requirements, include transfer pricing information
14 Sep - Mexico: Transfer pricing proposals in economic package for 2022
14 Sep - Namibia: Transfer pricing adjustments when transaction not at arm’s length
13 Sep - Singapore: New release of transfer pricing guidelines
13 Sep - Taiwan: Customs requirements when making one-time transfer pricing adjustments
3 Sep - Botswana: Threshold for preparing and filing transfer pricing documentation
August 2021
31 Aug - Germany: New administrative guidelines for transfer pricing
17 Aug - India: Tax relief, computation when book profit increase due to APA or secondary adjustments
11 Aug - Czech Republic: Transfer pricing issues remain under scrutiny
9 Aug - Hong Kong: Guidance addressing transfer pricing issues (COVID-19)
July 2021
29 Jul - Poland: Transfer pricing measures in proposed tax legislation
20 Jul - Iceland: Penalty provisions introduced for transfer pricing documentation noncompliance
19 Jul - Sri Lanka: Transfer pricing rules, documentation requirements
15 Jul - Bahrain: Country-by-country reporting and notification obligations
15 Jul - Oman: Clarification of suspension of country-by-country reporting
14 Jul - Netherlands: Formal investigation of tax rulings, transfer pricing issues (EU General Court)
13 Jul - Kenya: Country-by-country reporting measures enacted in Finance Act, 2021
13 Jul - Russia: Transfer pricing audits, focus on pre-audit analysis
10 Jul - G20 finance ministers conclude meeting with agreement for global minimum tax, other measures
8 Jul - Oman: Country-by-country reporting is suspended
6 Jul - Madagascar: Transfer pricing documentation requirements
2 Jul - KPMG report: OECD/G20 Inclusive Framework agreement on BEPS 2.0
June 2021
30 Jun - Germany: Provisions amending arm’s length principle, transfer pricing
29 Jun - Singapore: GST implications of common transfer pricing adjustments
29 Jun - South Africa: Transfer pricing adjustments and implications for VAT purposes
28 Jun - Jordan: Transfer pricing regulations are introduced
25 Jun - Azerbaijan: Update on country-by-country reporting
22 Jun - OECD: Reporting rules for platform operators regarding sellers in “sharing and gig economy”
21 Jun - Qatar: Deadline for filing Master files and Local files extended to 30 September 2021
18 Jun - Argentina: Extended due date for filing transfer pricing reports; other reporting relief measures
18 Jun - Malaysia: Common transfer pricing issues arising from intra-group services
15 Jun - EU: Update on status of “public” country-by-country reporting
11 Jun - Kenya: Country-by-country reporting proposal in budget 2021-2022
8 Jun - Switzerland: Implications of EU “public” country-by-country reporting for Swiss groups
7 Jun - KPMG report: Analysis and observations about tax measures in G7 communique
5 Jun - Communique from meeting of G7 finance ministers and central bank governors
2 Jun - EU: Political agreement on “public” country-by-country reporting requirements
1 Jun - Australia: Evidence relevant for determining arrangements are at arm’s length (High Court decision)
May 2021
28 May - Brazil: Status of possible transfer pricing rules
28 May - Hong Kong: What are possible considerations for BEPS 2.0?
25 May - Malta: Country-by-country reporting, penalties for non-compliance
24 May - Nigeria: Suspended country-by-country reporting requirements for MNE branches and subsidiaries
20 May - Australia: Intangibles arrangements; a deeper look at ATO’s draft practical compliance guideline
20 May - India: “Faceless” audits and future rules expected for transfer pricing audits
20 May - Kenya: Country-by-country proposals in Finance Bill, 2021
20 May - Tanzania: Rendering of intra-group services and transfer pricing audits
20 May - United States: Tax reform proposals—BEAT down, SHIELD up
19 May - Qatar: FAQs address transfer pricing documentation
18 May - Bahrain: FAQs on country-by-country reporting
18 May - Poland: Transfer pricing documentation, preliminary agreements and tax haven-related transactions
13 May - Bulgaria: Transfer pricing documentation; Local file for 2020 required by 30 June 2021
12 May - United States: Proposal to require country-by-country reporting of pre-tax profits, taxes paid
12 May - Singapore: Transfer pricing guide for multinational entity headquarters
12 May - Taiwan: Rules allowing one-time transfer pricing adjustment
12 May - Luxembourg: Tax rulings provided no selective advantage (EU General Court)
11 May - EU: Update on initiatives for public and non-public country-by-country reporting
11 May - KPMG report: Country-by-country reporting; notification requirements per country (updated)
6 May - Canada: APA statistics for 2020
April 2021
30 Apr - Singapore: R&D expenses under cost-sharing agreement (appellate court decision)
20 Apr - Malta: Update on expectations for transfer pricing rules
15 Apr - Switzerland: Tax authorities challenge transfer pricing of asset management offshore structures
15 Apr - Nigeria: Transfer pricing awareness survey (KPMG report)
9 Apr - Zambia: Amendments to country-by-country reporting rules
9 Apr - Belarus: Review of transfer pricing measures effective in 2021
9 Apr - UK: Proposals for new transfer pricing documentation, new annual related-party transaction return
8 Apr - Costa Rica: Advance pricing agreements, implementing guidance
March 2021
31 Mar - Mauritius: Country-by-country reporting deadline extended to 20 April 2021
30 Mar - United States: APMA program, APA statistics for 2020
26 Mar - Costa Rica: APA guidelines
26 Mar - UK: Updated country-by-country reporting schema
25 Mar - UK: Consultation on transfer pricing documentation requirements
24 Mar - Belgium: Overview of tax and transfer pricing audits of multinational entities
23 Mar - Mexico: APA negotiation process; compliance with information requests
23 Mar - Belgium: Deadline extended for filing Local file for assessment year 2021
23 Mar - Serbia: Arm’s length interest rates for 2021
22 Mar - China: Proposal for simplified process for unilateral APAs
19 Mar - Netherlands: “Control over risk” concept, implications for maritime and offshore industry
18 Mar - Mongolia: First transfer pricing tax assessment
17 Mar - Canada: CRA report on MAP program and statistics for 2019
16 Mar - Luxembourg: Guidance on mutual agreement procedures
11 Mar - South Africa: Transfer pricing implications of catch-up payments and retroactive adjustments
8 Mar - Netherlands: Mismatches in non-arm’s length transfer pricing, consultation on proposal
1 Mar - EU: Update on “public” country-by-country reporting proposal, following discussion by ministers
February 2021
26 Feb - OECD: United States drops “safe harbor” request on proposed digital tax rules
22 Feb - EU: Status of proposal for public country-by-country reporting
17 Feb - Argentina: Exchanges of country-by-country reports, agreement with United States
17 Feb - Korea: Transfer pricing-related amendments in tax legislation
17 Feb - South Africa: Transfer pricing adjustment upheld; no transfer pricing documentation
12 Feb - Australia: ATO focus on cross-border financing arrangements
11 Feb - Canada: APA cost-recovery charges cancelled
11 Feb - Germany: Proposed revisions to transfer pricing rules
10 Feb - Rwanda: Transfer pricing rules
4 Feb - Croatia: Arm’s length interest rate on loans between related parties for 2021
2 Feb - India: Transfer pricing measures in Union Budget 2021-2022
2 Feb - Qatar: Transfer pricing declarations required via tax administration portal (Dhareeba)
January 2021
28 Jan - Israel: Characterization of intragroup recharges for stock-based compensation
26 Jan - Thailand: Guidance implementing rules for transfer pricing and related-party transactions
21 Jan - Belarus: Proposed amendments to transfer pricing control provisions
21 Jan - OECD: Updated guidance on tax treaties (COVID-19)
19 Jan - OECD: Toolkit for developing countries, transfer pricing documentation rules
14 Jan - Russia: First bilateral APA is concluded
13 Jan - Belgium: Transfer pricing audits, new round of information requests
13 Jan - OECD: Compendium of comments on 2020 review of BEPS Action 14
8 Jan - KPMG report: Comments on OECD’s 2020 review of BEPS Action 14
2020 Articles
December 2020
30 Dec - Oman: Country-by-country notification deadline extended to 30 April 2021
23 Dec - KPMG report: OECD guidance on the transfer pricing implications of the COVID-19 pandemic
23 Dec - Italy: Budget bill includes proposed APA rollback mechanism, APA application fees
23 Dec - Turkey (Türkiye): Country-by-country reporting, automatic exchanges under CbC MCAA
22 Dec - Turkey (Türkiye): Extension of deadline for filing country-by-country report for 2019
22 Dec - Italy: Regulations implementing tax dispute resolution mechanisms and MAP processes
18 Dec - Malaysia: Transfer pricing FAQs
18 Dec - OECD: Guidance on transfer pricing implications of COVID-19 pandemic
17 Dec - KPMG report: Country-by-country reporting; overview of notification requirements per country
17 Dec - Australia: Transfer pricing recordkeeping options
17 Dec - Peru: Guidance for filing country-by-country reports for 2017, 2018 and 2019
16 Dec - OECD: Transfer pricing rules and implementation of hard-to-value-intangibles approach
16 Dec - Russia: Changes to APA process and measures related to controlled transactions
14 Dec - Bulgaria: New deadline for transfer pricing documentation
10 Dec - Australia: Updated ATO guidance, cross-border related-party financing arrangements
10 Dec - Vietnam: Transfer pricing rules are updated
7 Dec - Russia: Interest rates on controlled debt obligations, transfer pricing analysis not always required
4 Dec - Malaysia: Transfer pricing measures included in Finance Bill 2020
4 Dec - Peru: Country-by-country reports due 29 January 2021
3 Dec - Australia: Updated guidance on APAs
3 Dec - Denmark: New requirement for annual submission of transfer pricing documentation
3 Dec - Turkey (Türkiye): Deadline for filing country-by-country report (2019) is 31 December 2020
2 Dec - Ghana: Transfer pricing regulations (2020)
1 Dec - Australia: Due date for country-by-country reports deferred to 29 January 2021
November 2020
30 Nov - UK: Transfer pricing remains a significant focus for HMRC
27 Nov - Italy: Transfer pricing documentation guidelines (2020), replaces guidelines from 2010
20 Nov - Mexico-United States: Agreement on transfer pricing, tax treatment of maquiladoras
18 Nov - United States: Transfer pricing adjustments, deficiencies upheld (U.S. Tax Court opinion)
18 Nov - OECD: Report of MAP statistics for 2019
17 Nov - South Africa: Actions required after changes to SARS transfer pricing e-filing system
17 Nov - Thailand: New transfer pricing regulation
13 Nov - Belgium: Deadline for filing Local file is again extended
13 Nov - KPMG report: Year-end transfer pricing considerations
12 Nov - South Africa: Discussion paper on APAs
12 Nov - Zambia: Supreme Court upholds transfer pricing adjustment of mining company
11 Nov - Australia: Transfer pricing arrangements and JobKeeper payments, updated guidance (COVID-19)
10 Nov - Australia: Minor updates to ATO guidance on arm's length debt test
6 Nov - Lithuania: Updated transfer pricing documentation requirements
October 2020
29 Oct - OECD: New methodology for peer review of BEPS Action 13 country-by-country reporting
29 Oct - Poland: Legislative proposal to expand scope of transactions subject to transfer pricing rules
28 Oct - Romania: Transfer pricing adjustment, interest rate on intercompany loans (CJEU judgment)
27 Oct - Singapore: FAQs on transfer pricing implications of COVID-19
21 Oct - Peru: Country-by-country reporting update
20 Oct - Russia: Proposed changes to advance pricing agreement (APA) procedures
15 Oct - Brazil: Transfer pricing considerations (COVID-19)
15 Oct - Thailand: Penalty relief for transfer pricing disclosure forms, if e-filed by 30 December 2020
12 Oct - KPMG report: Summary and initial analysis of Pillar One Blueprint
12 Oct - KPMG report: Summary and initial analysis of Pillar Two Blueprint
12 Oct - Belgium: Local file, further extension of filing deadline to 16 November 2020
12 Oct - OECD: Pillar One and Pillar Two “Blueprints” and tax challenges of digital economy (text of reports)
6 Oct - Poland: Changes relating to transfer pricing in pending legislation
6 Oct - Switzerland: Transfer pricing opportunities flowing from tax reform incentive regimes
5 Oct - Turkey (Türkiye): Update on status of country-by-country reporting exchange agreement
1 Oct - United States: IRS practice unit, cost-sharing arrangements with stock-based compensation
1 Oct - Zambia: Transfer pricing measures included in 2021 budget
September 2020
30 Sep - KPMG report: Disrupting tax processes with artificial intelligence technology
29 Sep - Croatia: Reminder of transfer pricing compliance requirements
29 Sep - Poland: Expectations for transfer pricing-related inspections by tax authorities
24 Sep - OECD: Status report on country-by-country reporting
24 Sep - KPMG report: Managing transfer pricing and COVID-19 implications for financial service companies
21 Sep - Switzerland: Analyzing a cash pool from a transfer pricing perspective
17 Sep - Belgium: Transfer pricing compliance, Local file deadline extended to October 2020
11 Sep - Korea: Amendments in pending legislation would revise APA, MAP rules
9 Sep - Poland: Transfer pricing changes included in draft bill
4 Sep - Greece: APA rollback rules are expanded
2 Sep - Chile: New transfer pricing reporting requirements, Master file and Local file
2 Sep - United States: FAQs on North Carolina’s initiative for resolving transfer pricing issues
1 Sep - Belgium: Reminder of transfer pricing deadlines; reducing audit risk
August 2020
28 Aug - EU: Retroactive intercompany transfer pricing adjustments and customs valuation of imported goods
26 Aug - Australia: ATO focus on “offshore gearing” structures, related-party financing
26 Aug - UAE: Amendments to country-by-country reporting requirements
24 Aug - Taiwan: Draft amendments to transfer pricing assessment rules
21 Aug - India: Guidance for mutual agreement procedure (MAP)
18 Aug - Russia: Tax audit guidelines, verifying reasonableness of expenses for intra-group services