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18 Jan - Australia: ATO’s updated simplified transfer pricing recordkeeping practical compliance guideline

11 Jan - UK: New diverted profits tax facility aims at voluntary compliance, allows taxpayers to change transfer pricing policies

10 Jan - EU: Tax rulings granted by Netherlands to multinational corporation, EC state aid investigation opened

9 Jan - Argentina: Transfer pricing rules, implementing decree

9 Jan - Poland: Implementing decrees, transfer pricing regulations

7 Jan - Lithuania: New transfer pricing documentation requirements in 2019

3 Jan - Hong Kong: First unilateral advance pricing arrangement (APA) is concluded

26 Dec - India: Country-by-country reporting deadline extended

21 Dec - Latvia: Transfer pricing documentation requirements apply for 2018

19 Dec - Czech Republic: Assessing transfer prices, determining permanent establishment’s tax base

19 Dec - Japan: Transfer pricing proposals focus on hard-to-value intangibles

13 Dec - Saudi Arabia: Draft transfer pricing rules

13 Dec - Argentina: Country-by-country reporting requirements clarified, Argentine subsidiaries of MNE groups

13 Dec - Botswana: Transfer pricing and thin capitalisation legislation proposed

12 Dec - Qatar: Additional country-by-country reporting guidance, notification filing deadline extended

11 Dec - Nigeria: Reminder of 31 December deadline for transfer pricing compliance

6 Dec - Belarus: Transfer pricing proposals include repeal of arm’s length price “safe harbor”

30 Nov - Costa Rica: Considerations for preliminary transfer pricing reviews

30 Nov - UK: Key transfer pricing considerations for year-end closing

28 Nov - Zimbabwe: Transfer pricing annual return, documentation measures in 2019 budget

28 Nov - Australia: Transfer pricing ATO internal distributor risk guidance, initial impressions

27 Nov - Australia: Transfer pricing issues related to inbound distribution arrangements (draft guidance)

27 Nov - Uruguay: New transfer pricing documentation requirements

26 Nov - China: Country-by-country reporting compliance burden for certain outbound MNEs alleviated

26 Nov - Asia Pacific: Interplay of transfer pricing and customs valuation methods

26 Nov - Netherlands: Updated, stricter requirements for tax rulings with international character

26 Nov - Poland: New Transfer pricing measures effective in 2019

15 Nov - OECD: Peer review of dispute resolution (MAP); BEPS Action 14

14 Nov - Israel: Transfer pricing circular on business restructuring in MNE groups

12 Nov - Argentina: Country-by-country reporting guidance updated, modified

12 Nov - Belgium: Draft circular on transfer pricing, position of tax administration

12 Nov - Asia Pacific: Focus on transfer pricing, considerations for MNEs

12 Nov - Peru: Extended deadline for submitting country-by-country report for 2017

2 Nov - India: Renewal of APA—a first under the APA programme

30 Oct - Malaysia: FAQs on country-by-country reporting, sample notification letters

29 Oct - Australia: ATO final guidance on diverted profits tax, concurrent application with transfer pricing rules

29 Oct - KPMG report: Evaluation of OECD’s final guidance, transactional profit split method

25 Oct - Argentina: Country-by-country reporting, domestic subsidiaries of U.S. multinational entities

23 Oct - Costa Rica: Proposed changes to country-by-country reporting rules

17 Oct - Czech Republic: Intra-group services, transfer pricing assessment

17 Oct - Czech Republic: Transfer pricing issues in tax audits of individuals

17 Oct - Pakistan: Recordkeeping requirements of related-party transactions

16 Oct - Australia: Transfer pricing issues concerning centralised offshore non-core procurement hubs

10 Oct - OECD: Global mutual agreement procedure statistics for 2017

9 Oct - Israel: Transfer pricing circulars; methods and safe harbors for sales, services

5 Oct - Nigeria: Deadline for satisfying transfer pricing requirements, 31 December 2018

5 Oct - Nigeria: Insights into transfer pricing regulations, implications for MNEs

5 Oct - KPMG report: Legal agreements in transfer pricing, aligning form and fact

3 Oct - Thailand: New transfer pricing law, effective for accounting periods beginning on or after 1 January 2019

1 Oct - Qatar: Country-by-country reporting requirements

28 Sep - KPMG report: Post-BEPS issues concerning cost sharing arrangements in transfer pricing 

27 Sep - Andorra: Country-by-country reporting and notification rules

26 Sep - Korea: Transfer pricing-related proposals in 2019 tax revision legislation

25 Sep - Panama: New version of form for transfer pricing report

21 Sep - UK: Implications of Ireland’s proposed changes to transfer pricing regime for UK groups with Irish financing structures

19 Sep - Luxembourg: Non-taxation of U.S. multinational corporation not illegal state aid (EC investigation)

18 Sep - Nigeria: Public notice published, country-by-country reporting regulations

18 Sep - OECD: Saudi Arabia signs BEPS multilateral convention

18 Sep - United States: IRS reminders relating to Form 8975 “Country-by-Country Report”

17 Sep - Poland: Interactive forms available, simplified transfer pricing reports

13 Sep - Ireland: Proposed controlled foreign company (CFC) regime; profit determined using arm’s length, transfer pricing principles

13 Sep - OECD: Updated country-by-country reporting guidance; dividends received, employee numbers

12 Sep - Asia Pacific: Transfer pricing review (2018)

12 Sep - Malta: Reminder to file country-by-country reporting notification

10 Sep - China: WCO guide customs valuation and transfer pricing (2018 edition); implications for Chinese entities

10 Sep - KPMG report: OECD discussion draft, transfer pricing aspects of financial transactions

7 Sep - OECD: New transfer pricing country profiles (Costa Rica, Greece, South Korea, Panama, Seychelles, South Africa, Turkey)

31 Aug - New Zealand: Draft guidance for implementing BEPS legislation

31 Aug - UK: Notification requirements for country-by-country (CbC) reporting; second notification may be required

30 Aug - Nigeria: New transfer pricing regulations effective retroactively, March 2018

17 Aug - Chile: Customs allows transfer pricing valuation, as established by APAs

16 Aug - United States: Eighth Circuit vacates Tax Court’s determination of transfer pricing method

7 Aug - United States: Ninth Circuit withdraws decision in cost-sharing arrangements case, new panel to consider appeal

3 Aug - OECD: Does discussion draft on transfer pricing for financial transactions pose more questions than it answers?

3 Aug - UK: HMRC report on transfer pricing and diverted profits tax (DPT) statistics for 2017-2018

3 Aug - Peru: Country-by-country reports, transfer pricing documentation due in November 2018

25 Jul - Canada: Statistics from 2017 advance pricing arrangement (APA) program; record number of APA cases

25 Jul - United States: IRS updates country-by-country reporting guidance, information

24 Jul - United States: Ninth Circuit reverses Tax Court, upholds cost-sharing regulations

24 Jul - Australia: Proposal to expand “significant global entity” definition, aligning country-by-country reporting with OECD model requirements

24 Jul - Belgium: Civil penalties for transfer pricing documentation compliance failures

20 Jul - Poland: Proposed changes to transfer pricing rules

18 Jul - Netherlands: Implications of Dutch transfer pricing decree on OECD discussion draft on transfer pricing of financial transactions

17 Jul - United States: Transfer pricing in the age of tax reform

16 Jul - India: “Substantive revision” of bilateral APA with UK

13 Jul - Nigeria: Country-by-country reporting guidelines

12 Jul - Czech Republic: What to expect in a transfer pricing inspection

12 Jul - France: Transfer pricing documentation requirements, clarified and detailed

11 Jul - KPMG report: Initial impressions of OECD discussion draft on transfer pricing for financial transactions

10 Jul - Curaçao: Legislation implementing BEPS recommendations includes transfer pricing reporting obligations

6 Jul - New Zealand: New BEPS law enacted, includes transfer pricing measures

5 Jul - Hong Kong: Passage of transfer pricing legislation (BEPS bill); most provisions effective from assessment year 2018/2019

5 Jul - India: Guidance on confidentiality, appropriate use of country-by-country reports

3 Jul - Nigeria: Transfer pricing update, including country-by-country reporting

3 Jul - OECD: BEPS discussion draft, transfer pricing aspects of financial transactions

29 Jun - OECD: Comments received on future revisions to Transfer Pricing Guidelines

28 Jun - France: Basis for local taxation (CVAE) includes transfer pricing re-assessments

22 Jun - Chile: Annual transfer pricing declaration for 2017, due 29 June

21 Jun - Belgium: Transfer pricing documentation, reminder of due dates

21 Jun - Nigeria: Country-by-country reporting regulations are published

21 Jun - OECD: Guidance on hard-to-value intangibles, transactional profit split method (BEPS Actions 8 and 10)

20 Jun - OECD: KPMG comments on future revisions to Transfer Pricing Guidelines

19 Jun - Thailand: Transfer pricing proposals for related-party disclosures advance; expected effective date 1 January 2019

12 Jun - Australia: ATO continued focus on identifying high-risk transfer pricing arrangements

12 Jun - India: No international transaction with related party, absent documentation or agreement for advertising, marketing, and promotion expenses

8 Jun - India: Marketing survey expenses, technical training held at arm’s length

6 Jun - Canada: OECD peer review of country-by-country reporting

6 Jun - New Zealand: BEPS implementing legislation update; transfer pricing and thin capitalisation rules

1 Jun - Germany: Transfer pricing adjustments, involving non-resident related company relationships not at arm’s length

24 May - OECD: First peer reviews of country-by-country reports, in advance of June 2018 rollout

18 May - United States: New country-by-country reporting FAQs, filing information

18 May - Latvia: Transfer pricing documentation; focus on Master and Local files

17 May - Israel: Related-party cross-border services; markup of costs (“cost plus”) remuneration (Supreme Court judgment)

16 May - Italy: New transfer pricing guidelines address methodology, arm’s length, documentation standards

14 May - Netherlands: New transfer pricing decree incorporates OECD standards

14 May - South Africa: Penalties for non-compliance; country-by-country reporting, transfer pricing returns

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

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”

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

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

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

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

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 - United States: IRS practice units, common ownership or control under Code section 482

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

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 - EU: New rules, process for resolving tax treaty-related disputes

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

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

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

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

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

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

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

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 - United States: 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

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)

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

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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