Transfer Pricing
Transfer Pricing
TaxNewsFlash-Transfer Pricing — KPMG's reports of transfer pricing developments from across the globe
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Recent Articles
January 2021
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: Country-by-country reporting, automatic exchanges under CbC MCAA
22 Dec - Turkey: 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: 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: 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
12 Aug - Philippines: Guidance on completing related-party transaction Form No. 1709
7 Aug - France: Annual transfer pricing return, filing deadline postponed (COVID-19)
7 Aug - South Africa: Proposal to amend “affected transaction” definition for transfer pricing purposes
5 Aug - Ecuador: Transfer pricing methodology for banana exports; other transfer pricing reforms
July 2020
30 Jul - United States: IRS concept unit on accuracy-related penalties, tax professionals urge caution
29 Jul - Australia: Transfer pricing rules updated to align with OECD guidelines
20 Jul - KPMG report: Addressing liquidity issues using intercompany pricing tools (COVID-19)
17 Jul - Hong Kong: Guidance on APA procedures
16 Jul - Australia: Transfer pricing arrangements and JobKeeper payments (COVID-19)
10 Jul - Belgium: Guidance on transfer pricing reporting, BEPS 13 forms
10 Jul - KPMG report: Getting to know the value-chain analysis
7 Jul - OECD: Global tax reporting framework for digital platforms
6 Jul - Oman: Country-by-country reporting, transfer pricing guidelines anticipated
6 Jul - Poland: Postponed deadlines for transfer pricing documentation, reporting (COVID-19)
June 2020
30 Jun - India: Section 10A tax benefit and additional income from MAP
29 Jun - Italy: Tax dispute resolution mechanisms, new mutual agreement procedures
26 Jun - Panama: Transfer pricing report submission date is postponed (COVID-19)
25 Jun - South Africa: Tax authorities to focus on transfer pricing, Supplementary Budget 2020
24 Jun - Netherlands: Updated decree, rules for mutual agreement procedures
23 Jun - Australia: Transfer pricing guidance; ATO response to COVID-19
23 Jun - Netherlands: Transfer pricing issues in context of COVID-19
19 Jun - United States: Treasury Secretary seeks “pause” in OECD Pillar 1 discussions of digital economy
19 Jun - Nigeria: Tax and transfer pricing returns for calendar-year companies due 31 July (COVID-19)
18 Jun - OECD: Statement about ongoing negotiations, taxation of digital economy
17 Jun - United States: Reports of withdrawal from talks with EU on digital services tax
17 Jun - Australia: Updated information for country-by-country reporting 2020
12 Jun - KPMG report: APAs and COVID-19
11 Jun - Australia: New MAP guidelines, arbitration arrangements for resolving international tax disputes
10 Jun - Canada: APA statistics for 2019
9 Jun - KPMG report: COVID-19 and transfer pricing policy; lookback analysis of routine returns
5 Jun - Argentina: Transfer pricing compliance rules, reporting deadline deferred to July 2020
5 Jun - Saudi Arabia: Transfer pricing guidelines (second edition)
May 2020
29 May - KPMG report: Intangible property transfer pricing in an economic downturn
28 May - Nigeria: Transfer pricing method; appellate tribunal decision in case of first impression
26 May - India: Amendments to MAP application and procedural rules
26 May - Serbia: Tax and transfer pricing implications to be considered (COVID-19)
21 May - South Africa: Proposal to limit interest deductions on cross-border debt
20 May - United States: Competent authority, changes regarding requests and APA consultations (COVID-19)
18 May - United States: Transfer pricing adjustments, potential customs tariff opportunities (COVID-19)
15 May - Argentina: Transfer pricing compliance rules, reporting dates established
14 May - Russia: Draft legislative amendments to revise APA measures
13 May - OECD: Consultation on 2020 review of country-by-country reporting
7 May - Peru: No changes to transfer pricing filing, reporting obligations
5 May - Colombia: No changes to transfer pricing reporting deadlines
5 May - Sweden: Transfer pricing and financial transactions
5 May - KPMG report: Bolster the resilience of the transfer pricing model (COVID-19)
5 May - KPMG report: Transfer pricing implications for intercompany loans (COVID-19)
April 2020
27 Apr - Poland: Interactive transfer pricing form, Local file
27 Apr - Portugal: Postponed deadline for transfer pricing documentation (COVID-19)
27 Apr - United States: Transfer pricing strategies for private equity portfolio companies (COVID-19)
24 Apr - Belgium: COVID-19 implications from a transfer pricing perspective
23 Apr - Sweden: Transfer pricing treatment of IP in third-party acquisitions
22 Apr - Malaysia: Further extension of country-by-country reporting deadlines (COVID-19)
22 Apr - Turkey: Transfer pricing documentation requirements, implementation update
21 Apr - Zimbabwe: Extended deadline, transfer pricing returns for 2019 (COVID-19)
15 Apr - Bangladesh: Transfer pricing inquiries of multinational corporations
15 Apr - United States: IRS provides FAQs on transfer pricing documentation “best practices”
10 Apr - Canada: Transfer pricing implications (COVID-19)
9 Apr - Czech Republic: Transfer pricing considerations (COVID-19)
7 Apr - Indonesia: Updated regulations on advance pricing agreements
3 Apr - OECD: Tax implications for cross-border workers, other cross-border matters (COVID-19)
3 Apr - Hong Kong: Revised guidance, taxation of digital economy and intersection with transfer pricing
3 Apr - Malaysia: Extension of country-by-country reporting deadline to 15 May 2020 (COVID-19)
3 Apr - South Africa: Reminder of transfer pricing documentation compliance requirements
2 Apr - Poland: Transfer pricing return filing, extended due date (COVID-19)
1 Apr - Denmark: Transfer pricing documentation, extension of deadline (COVID-19)
1 Apr - Argentina: Transfer pricing compliance rules, effective date once again delayed
March 2020
31 Mar - Bermuda: Extended deadline for country-by-country reporting (COVID-19)
31 Mar - Hong Kong: Extended notification deadline, country-by-country reporting (COVID-19)
31 Mar - Nigeria: Transfer pricing e-filing portal
30 Mar - New Zealand: Relief relating to APAs, response to coronavirus (COVID-19)
26 Mar - China: Transfer pricing arrangements and challenges (COVID-19)
24 Mar - India: Digital taxation, enlarging the scope of “equalisation levy”
22 Mar - Denmark: Proposals for changes to transfer pricing documentation rules
17 Mar - Zimbabwe: Transfer pricing return for 2019 tax year
16 Mar - Denmark: Transfer pricing documentation deadline, reminder
12 Mar - Serbia: Related-party interest rates for 2020, transfer pricing documentation implications
9 Mar - OECD: Comments concerning 2020 review of country-by-country reporting
5 Mar - Zambia: Disclosures required for related-party relationships
5 Mar - Hong Kong: Arrangement for automatic exchange of country-by-country reports with China
4 Mar - South Africa: Tax authority to use transfer pricing risk profiling to verify compliance
2 Mar - Argentina: Transfer pricing compliance rules, effective date delayed again
February 2020
27 Feb - South Africa: Transfer pricing measures in budget 2020-2021
26 Feb - Belgium: Final version, circular letter on transfer pricing
25 Feb - Nigeria: Benchmarking related-party transactions, transfer pricing methods (tribunal decision)
25 Feb - Turkey: Country-by-country reporting, transfer pricing documentation guidance
24 Feb - Germany: Arm’s length principle, proposed amendments
21 Feb - Hong Kong: Possible implications of OECD transfer pricing guidance on financial transactions
21 Feb - China: Country-by-country reporting update; transfer pricing audit risks
18 Feb - South Africa: Uncertainty about transfer pricing treatment of financial transactions
17 Feb - OECD: “BEPS 2.0” and taxation of digitalised economy, in a nutshell
13 Feb - KPMG report: Insights on OECD’s revised “Unified Approach” to tax challenges of digitalisation
13 Feb - KPMG report: OECD transfer pricing (final) guidance on financial transactions: Initial impressions
13 Feb - OECD: Webcast on tax challenges of digitalisation; Pillar One and Pillar Two proposals
12 Feb - Czech Republic: Transfer pricing issues identified in financial statement reviews
11 Feb - OECD: Transfer pricing guidance on financial transactions
11 Feb - KPMG report: Summary of recent transfer pricing developments, “brave new world”
10 Feb - UK: Arbitration directive-related rules; enhancing cross-border dispute resolution
6 Feb - OECD: Consultation document on review of country-by-country reporting (BEPS Action 13)
5 Feb - Panama: Country-by-country reporting deadline for 2018 extended
4 Feb - Botswana: Overview of transfer pricing rules
4 Feb - Brazil: Possible alignment of transfer pricing rules to OECD Transfer Pricing Guidelines
3 Feb - India: Transfer pricing proposals in Union Budget 2020
January 2020
31 Jan - OECD: Update on digital economy tax issues; “Pillar One” possible safe harbour
23 Jan - Canada: MAP statistics for 2018
23 Jan - Puerto Rico: Transfer pricing documentation rules, for deduction of intercompany charges
22 Jan - Australia: Guidance addresses non-arm’s length arrangements involving intangible assets
21 Jan - Taiwan: Customs guidance on one-time transfer pricing adjustment
15 Jan - Panama: Guidance for country-by-country reporting, and filing portal
2019 Articles
December 2019
27 Dec - Malaysia: New transfer pricing audit framework (2019)
23 Dec - OECD: Guidance for tax administrations, MNE groups on country-by-country reporting
20 Dec - Thailand: New transfer pricing disclosure form may increase customs valuation risk
18 Dec - Nigeria: Country-by-country reporting, filing deadline for companies with 31 December year-end
17 Dec - Costa Rica: Transfer pricing reports required from taxpayer group
16 Dec - Argentina: Delayed effective date, transfer pricing compliance rules
13 Dec - Serbia: Country-by-country reporting rules are enacted
12 Dec - India: Tribunal allows section 10A deduction on additional income resulting from APA
12 Dec - KPMG report: Transfer pricing from an operations perspective
12 Dec - Canada: Year-end preparation, checklist for transfer pricing
11 Dec - Costa Rica: Draft guidelines for processing advance pricing agreements (APAs)
4 Dec - KPMG report: Comments on OECD’s global anti-base erosion (GloBE) proposal under Pillar Two
4 Dec - OECD responds to U.S. Treasury’s letter on digital services tax
4 Dec - United States: Treasury opposition to digital services tax initiatives, support for Pillar One
November 2019
27 Nov - Taiwan: Guidance for taxpayers making a one-time transfer pricing adjustment
21 Nov - Portugal: Court decision, underpriced controlled transaction and application of TNMM
20 Nov - Thailand: Transfer pricing disclosure form
19 Nov - Australia: More time to submit country-by-country reports
19 Nov - Portugal: Details of transfer pricing documentation requirements, other recent developments
15 Nov - Costa Rica: Transfer pricing documentation guidelines (Master and Local files)
15 Nov - Zimbabwe: Transfer pricing documentation, 2020 budget update
12 Nov - United States: Ninth Circuit denies en banc rehearing, section 482 stock-based compensation case
12 Nov - KPMG report: Comments on “Pillar One” approach to address digital economy tax issues
8 Nov - New Zealand: Inland Revenue’s focus on BEPS and MNE tax compliance includes transfer pricing
8 Nov - OECD: Global anti-base erosion proposal under Pillar Two; consultation document released
6 Nov - OECD: More guidance on country-by-country reporting, MNE groups
4 Nov - Portugal: Transfer pricing documentation, other measures effective 2020
October 2019
25 Oct - KPMG report: Tax, transfer pricing, and transformation; what asset managers may be forgetting
16 Oct - KPMG report: Managing transfer pricing; focus on process from start to finish for better outcomes
10 Oct - Australia: Transfer pricing focus in life sciences sector
9 Oct - OECD: Proposal to address digital economy tax issues, “Pillar One” approach
8 Oct - Argentina: Draft guidance on transfer pricing compliance procedures
2 Oct - Greece: Country-by-country notifications, electronic submissions required
2 Oct - Nigeria: Plans for electronic filing of transfer pricing forms, country-by-country reports
1 Oct - Zambia: Transfer pricing measures included in 2020 budget
September 2019
30 Sep - Qatar: Country-by-country notification and reporting requirements
27 Sep - UK: Update on “nudge” letters for diverted profits tax, transfer pricing issues
26 Sep - Australia: Transfer pricing risks and offshore drilling-related leasing arrangements
25 Sep - Denmark: Transfer pricing documentation to be filed with tax return (draft bill)
25 Sep - Ireland: Hearing in tax rulings case (EU General Court)
24 Sep - Luxembourg: EU General Court upholds EC challenge to tax ruling
24 Sep - Netherlands: EU General Court annuls EC action in APA case
20 Sep - India: Update on APA program, personnel changes
19 Sep - EU: Status update on advance pricing arrangements
16 Sep - Belgium: EC investigations of “excess profit” tax rulings granted multinational companies
16 Sep - OECD: MAP statistics for 2018; transfer pricing case dispute resolutions
13 Sep - Ireland: Proposed transfer pricing rule changes, possibly effective January 2020
3 Sep - Australia: Taxpayer’s comparables prevail in transfer pricing case
3 Sep - Ireland: Possible changes to transfer pricing rules
3 Sep - OECD: Update on second peer review, country-by-country reporting
August 2019
30 Aug - Australia: ATO draft guidance, risk assessment and arm’s length debt test
26 Aug - KPMG report: Transfer pricing and technology, for today and tomorrow
15 Aug - KPMG report: Corporate tax transparency in the BEPS era
15 Aug - Australia: ATO official outlines transfer pricing areas of focus
13 Aug - OECD: “Stage 2” peer review of tax dispute resolution (MAP) (BEPS Action 14)
12 Aug - Bulgaria: Mandatory transfer pricing documentation; new rules for Master and Local files
5 Aug - United States: IRS withdraws LB&I directive on cost-sharing arrangements
2 Aug - UK: HMRC targets profit diversion, transfer pricing risk for MNEs
2 Aug - Zimbabwe: Transfer pricing rules, clarification to thin capitalisation measures
July 2019
31 Jul - Argentina: Extended compliance deadlines for transfer pricing
29 Jul - EU: Statistics of APAs and MAPs for 2018
29 Jul - KPMG report: Evaluating transfer pricing as part of risk management
25 Jul - France: Digital services tax (3%) is enacted
25 Jul - New Zealand: Update on digital services tax consultation
22 Jul - G7 finance ministers, agreement on taxation of digital economy
22 Jul - Hong Kong: Guidance concerning transfer pricing documentation, country-by-country reports
19 Jul - Botswana: Transfer pricing regulations, effective July 2019
19 Jul - Canada: APA statistics for 2018
19 Jul - UK: Transfer pricing and evolving operating models for financial institutions
18 Jul - Costa Rica: Transfer pricing guidance
17 Jul - Brazil: Project to align Brazil's transfer pricing rules to OECD guidelines
16 Jul - Sweden: Benchmark analysis and arm’s length determination (transfer pricing court case)
12 Jul - Czech Republic: Companies receiving investment incentives face transfer pricing issues
12 Jul - Czech Republic: New instructions for related-party transactions, transfer pricing guidelines
12 Jul - Netherlands: EC publishes non-confidential version, state aid investigation of Dutch tax rulings
12 Jul - KPMG report: BEPS and asset management; implications for investment funds and asset managers
12 Jul - Austria: Update on proposals for digital services tax
12 Jul - UK: Initial impressions of digital services tax draft legislation
11 Jul - France: Digital services tax approved by parliament
11 Jul - UK: Proposal for digital services tax, in draft Finance Bill
11 Jul - UAE: Country-by-country reporting requirements
10 Jul - United States: Country-by-country reporting updates from IRS
8 Jul - Czech Republic: Update on digital services tax
8 Jul - Qatar: Update on country-by-country reporting requirements
8 Jul - Switzerland: LIBOR phaseout implications for tax and transfer pricing
3 Jul - Thailand: Draft regulatory proposals for transfer pricing documentation
2 Jul - Netherlands: Final policy statement, international tax rulings
2 Jul - Vietnam: Taxation of e-commerce transactions, remote digital sales
June 2019
27 Jun - OECD: Update on tax challenges arising from digitalisation of economy
27 Jun - OECD: Updated XML schemas for country-by-country report exchanges and tax ruling information
27 Jun - France: Update on digital services tax; enactment anticipated
24 Jun - United States: IRS position on multiple RAB shares in CSAs
18 Jun - OECD: Transfer pricing country profiles for Chile, Finland, Italy
17 Jun - KPMG report: BEPS Actions 8-10, aligning transfer pricing outcomes with value creation
13 Jun - Nigeria: Transfer pricing returns due 30 June, companies with 31 December year-end
13 Jun - United States: Ninth Circuit reverses Tax Court (again), upholds cost-sharing regulations
12 Jun - Bahamas: Status of country-by-country reporting and notification
12 Jun - Singapore: Transfer pricing guidelines for commodity marketing and trading companies
7 Jun - United States: Ninth Circuit reverses Tax Court, validity of cost-sharing arrangement regulations
7 Jun - UK: Considering tax implications of digitalisation of economy
7 Jun - UK: More diverted profit “nudge” letters expected from HMRC
6 Jun - Panama: Country-by-country reporting requirements
5 Jun - New Zealand: Digital services tax; discussion document released
5 Jun - United States: IRS directive, selecting transfer pricing issues involving cost-sharing arrangements
May 2019
31 May - OECD: Plan for resolving tax challenges of digital economy, taxing multinational entities
31 May - UK: Proposals concerning taxation of offshore intangible receipts
29 May - Panama: Transfer pricing report of related-party transactions, June 2019 deadline
29 May - Zimbabwe: Transfer pricing rules, overview
27 May - Argentina: Unified requirements, deadline for transfer pricing reports and returns
23 May - Poland: New rules relating to country-by-country reporting, exchange of information
20 May - Czech Republic: Digital tax proposals expected in 2020 tax package
14 May - Italy: Ruling request process, certainty with regard to permanent establishments
11 May - KPMG report: Multilateral solution to tax challenges of digitalization; goal for 2020
8 May - UK: Details about proposed digital services tax
3 May - OECD: Transfer pricing and governance implications for lessors
April 2019
26 Apr - Netherlands: Plans for revised, renewed international tax rulings policy
26 Apr - Zambia: First judicial guidance, arm’s length arrangements between related parties
18 Apr - KPMG video: OECD's proposals on taxing the digital economy, transfer pricing implications
17 Apr - United States: IRS compliance campaign, arm’s length price payments to captive services provider
15 Apr - United States: Pricing method, services cost method eligibility under U.S. BEAT provision
9 Apr - India: Country-by-country reports due 30 April, Indian subsidiaries of U.S. multinational entities
5 Apr - EU: Joint Transfer Pricing Forum, report on profit-split method
5 Apr - Poland: Proposals for “simplified APA”
3 Apr - Ireland: Response to public consultation on new transfer pricing regime
3 Apr - Nigeria: MAP guidelines, resolving double taxation disputes
3 Apr - UK: Discussion about government assessment, response to digitalisation
March 2019
27 Mar - United States: APMA program, APA statistics for 2018
27 Mar - India: Arrangement for country-by-country report exchanges with United States is signed
22 Mar - OECD: Taxation of digital economy, public consultation update
22 Mar - United States: Foreign-initiated adjustments, competent authority guidance (IRS practice unit)
20 Mar - Canada: Transfer pricing measures in federal budget
20 Mar - India: No transfer pricing adjustment, profit margin greater than comparables
19 Mar - EU: Taxation of digital economy; considering possible outcomes
18 Mar - Poland: Application of transfer pricing regulations clarified for 2018 transactions
15 Mar - India: Agreement with United States, exchange of country-by-country reports
14 Mar - India: Criteria for selecting transfer pricing comparable companies
14 Mar - Peru: Extended deadlines for filing country-by-country reports for 2017, 2018
13 Mar - Canada: MAP program summary, statistics for 2017
12 Mar - Peru: Tax authorities communication regarding local filing of country-by-country reports for FY 2017
11 Mar - UK: Proposed digital services tax; overview and possible implications for U.S. businesses
11 Mar - United States: IRS transfer pricing teams must consult competent authority
8 Mar - United States: Competent authority process, under tax treaty’s MAP article
8 Mar - Hong Kong: Transfer pricing compliance for 2018-19 year of assessment
8 Mar - OECD: KPMG comments concerning consultation on tax challenges of digitalisation
8 Mar - UK: Insight into HMRC’s profit diversion compliance facility
7 Mar - Luxembourg: EC state aid investigation, tax rulings granted Finnish-headquartered company
6 Mar - France: Draft proposal for digital services tax
4 Mar - Serbia: Related-party interest rates for 2019, transfer pricing documentation implications
4 Mar - United States: “Functional cost diagnostic model” for review of APA requests
1 Mar - UK: HMRC profit-diversion compliance facility; verifying transfer pricing and BEPS compliance
February 2019
27 Feb - United States: IRS reminders on filing country-by-country reports on Form 8975
25 Feb - Brazil: Updated MAP rules, guidelines
21 Feb - Slovakia: Guidelines for transfer pricing documentation
20 Feb - Ireland: Consultation on new transfer pricing regime
19 Feb - OECD: Comment period extended, tax challenges of digitalisation
19 Feb - Saudi Arabia: Transfer pricing regulations finalized, accompanying FAQs released
15 Feb - Czech Republic: Transfer pricing and audits of financial statements
14 Feb - OECD: Initial impressions of consultation paper on tax challenges of digitalisation
11 Feb - Korea: Tax amendments reflecting transfer pricing standards
8 Feb - United States: Statistics of country-by-country reports for 2016
8 Feb - United States: Senate Finance leadership’s position on proposed EU digital services tax
8 Feb - Spain: Digital services tax proposed in pending legislation
4 Feb - Denmark: Landmark transfer pricing decision from Supreme Court
1 Feb - Botswana: Transfer pricing rules, effective July 2019
January 2019
31 Jan - Peru: Status of country-by-country report exchanges under “MCAA CbC”
31 Jan - Hong Kong: Reminder of country-by-country notification, reporting requirements
30 Jan - OECD: Initial impressions about digital economy project
29 Jan - OECD: Update on digital economy work; arm’s length implications
28 Jan - United States: Possible penalty exposure, cost-sharing agreements and stock-based compensation
25 Jan - Kazakhstan: Transfer pricing documentation; APA procedures
24 Jan - China: APA report, data covering period 2005 to 2017
18 Jan - Australia: ATO’s updated simplified transfer pricing recordkeeping practical compliance guideline
9 Jan - Argentina: Transfer pricing rules, implementing decree
9 Jan - Poland: Implementing decrees, transfer pricing regulations
Taxation of the Digitalized Economy
KPMG's reports of developments concerning the tax treatment of the digital economy, including digital services tax and the taxation of online, remote sales
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