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Transfer Pricing

Transfer Pricing

TaxNewsFlash-Transfer Pricing — KPMG's reports of transfer pricing developments from across the globe


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TaxNewsFlash-Transfer Pricing

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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 - 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

September 2018

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)

July 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

March 2018

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

January 2018

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

2017 Articles

December 2017

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

November 2017

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

October 2017

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

August 2017

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

June 2017

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

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

>> Read more

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