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Recent Articles

June 2022

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

21 Jun - Cambodia: Guidance regarding loans between related parties; interest rate and supporting documentation

20 Jun - EU: Report of ECOFIN to European Council on tax issues including Pillar Two, minimum tax, harmful tax practices, preferential tax regimes, non-cooperative jurisdictions

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

23 May - Australia: Labor party wins 2022 election, tax policies include public country-by-country (CbC) reporting

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

11 May - Vietnam: Recommended focus on tax audit and inspection of high-risk industries and areas (transfer pricing)

10 May - Czech Republic: Additional tax assessment based on overall profitability for unrelated-party transactions (court decision)

9 May - Israel: Court decision on business restructuring and deemed transfer of business functions, assets and risks

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

2 May - UK: Transfer pricing statistics (FY 2021)

April 2022

28 Apr - KPMG report: Transfer pricing and the audit committee agenda, implementation steps

26 Apr - United States: Country-by-country (CbC) report in the transfer pricing risk analysis process (IRS practice unit)

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)

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

14 Feb - Poland: Grant of free-of-charge guarantee treated as “transaction” for transfer pricing purposes (court decision)

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

6 Feb - KPMG report: Public consultation document on Pillar One—draft model rules for nexus and revenue sourcing

4 Feb - OECD: Public consultation on two-pillar solution launched; first building block under Pillar One released

2 Feb - Nigeria: Transfer pricing outlook for 2022

2021 Articles

December 2021

22 Dec - EU: Directive to implement Pillar Two is proposed

22 Dec - KPMG report: Initial analysis of Pillar Two model rules for global minimum tax under OECD/G20 Inclusive Framework

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 - Australia: Independent parties would not have agreed to changes to financing arrangement (court decision)

17 Dec - KPMG report: Uneven transfer pricing implications of COVID-19 pandemic

16 Dec - Luxembourg and Ireland: Opinion of CJEU Advocate General regarding tax rulings issued to multinational entities

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 - United States and Turkey (Türkiye): Competent Authority Arrangement regarding exchange of country-by-country reports

1 Dec - Zambia: Transfer pricing measures included in 2022 budget

1 Dec - EU: “Public” country-by-country reporting directive published in EU Official Journal

May 2021

28 May - KPMG report: Comments on proposed changes to Commentaries in OECD Model Tax Convention, Article 9 and related articles

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 - Australia: Draft compliance guideline, transfer pricing and international arrangements involving intangible assets

19 May - EU: Plan for implementing BEPS 2.0 and each of two Pillars; annual publication of effective corporate tax rate by large companies operating within EU

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

17 May - India: Effects of APA on taxable income (royalty) received by foreign taxpayer that is not a party to the APA

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

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

5 Mar - EU: Negotiating positions of EU Council and European Parliament, proposal for “public” country-by-country reporting

3 Mar - Germany: Transfer pricing documentation guidelines, cross-border transactions between related parties

1 Mar - EU: Update on “public” country-by-country reporting proposal, following discussion by ministers

1 Mar - Qatar: Transfer pricing documentation guidelines

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 - OECD: Compendium of comments on “Blueprints” concerning tax challenges from digitalisation of the economy

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 - KPMG report: Comments concerning OECD “Blueprints” and tax challenges from digitalisation of the economy

14 Dec - Bulgaria: New deadline for transfer pricing documentation

14 Dec - UK: MAP requests under EU Arbitration Convention no longer accepted after 2020, possible treaty implications

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 - Belgium: Tax rulings, downward adjustments to profits constituting “aid scheme” (CJEU Advocate General’s opinion)

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

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 - Czech Republic: Transfer prices incorrectly set by companies receiving investment incentives (court judgment)

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