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: 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 - 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: 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: 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

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

22 Jun - United States: Supreme Court denies certiorari, appeal from Ninth Circuit upholding cost-sharing regulations as valid 

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)

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 - United States: Considerations for modifying or unwinding related-party transactions, responding to coronavirus (COVID-19)

24 Mar - India: Digital taxation, enlarging the scope of “equalisation levy”

24 Mar - Mexico: Non-deduction of payments to related parties in low-tax jurisdictions, interest deduction limitations

23 Mar - Switzerland: Transfer pricing considerations for multinational companies, responding to coronavirus (COVID-19)

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

21 Feb - Australia: More considerations for Australian businesses of OECD transfer pricing guidance for financial transactions

20 Feb - Australia: Implications for Australian businesses, OECD transfer pricing guidance on financial transactions

20 Feb - Australia: Transfer pricing risks and offshore drilling-related leasing arrangements (final guidance)

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