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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 - United States: IRS directive, selecting transfer pricing issues involving cost-sharing arrangements

31 May - OECD: Plan for resolving tax challenges of digital economy, taxing multinational entities

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

14 May - Italy: Ruling request process, certainty with regard to permanent establishments

8 May - UK: Details about proposed digital services tax

3 May - OECD: Transfer pricing and governance implications for lessors

3 May - Belarus: Overview of new transfer pricing rules

2 May - Czech Republic: Proposal for digital services tax

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

10 Apr - United States: Congressional tax committee leaders express support for OECD efforts, digital services taxes

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

1 Apr - United States: New tool for APA submissions

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 - Australia: Guidance on inbound distribution arrangements, transfer pricing policies and arm’s length nature

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

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

4 Feb - Denmark: Landmark transfer pricing decision from Supreme Court

1 Feb - Botswana: Transfer pricing rules, effective July 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

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

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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