Subscribe to TaxNewsFlash. Questions? Send an email.

>> Return to the TaxNewsFlash "global" homepage

>> Go to the TaxNewsFlash U.S. homepage

>> Go to the BEPS Action 13: Latest country implementation update

_{KPMG's global editions of TaxNewsFlash are maintained and distributed by KPMG in the United States. When you click the hyperlinks below, you will be directed away from this page owned by KPMG International and redirected to a page owned by KPMG in the United States.}  

22 Jun - OECD: Reporting rules for platform operators regarding sellers in “sharing and gig economy”

21 Jun - Qatar: Deadline for filing Master files and Local files extended to 30 September 2021

18 Jun - Argentina: Extended due date for filing transfer pricing reports; other reporting relief measures

18 Jun - Malaysia: Common transfer pricing issues arising from intra-group services

15 Jun - EU: Update on status of “public” country-by-country reporting

11 Jun - Kenya: Country-by-country reporting proposal in budget 2021-2022

8 Jun - Switzerland: Implications of EU “public” country-by-country reporting for Swiss groups

7 Jun - KPMG report: Analysis and observations about tax measures in G7 communique

5 Jun - Communique from meeting of G7 finance ministers and central bank governors

2 Jun - EU: Political agreement on “public” country-by-country reporting requirements

1 Jun - Australia: Evidence relevant for determining arrangements are at arm’s length (High Court decision)

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

30 Apr - Singapore: R&D expenses under cost-sharing agreement (appellate court decision)

20 Apr - Malta: Update on expectations for transfer pricing rules

15 Apr - Switzerland: Tax authorities challenge transfer pricing of asset management offshore structures

15 Apr - Nigeria: Transfer pricing awareness survey (KPMG report)

9 Apr - Zambia: Amendments to country-by-country reporting rules

9 Apr - Belarus: Review of transfer pricing measures effective in 2021

9 Apr - UK: Proposals for new transfer pricing documentation, new annual related-party transaction return

8 Apr - Costa Rica: Advance pricing agreements, implementing guidance

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

26 Feb - OECD: United States drops “safe harbor” request on proposed digital tax rules

22 Feb - EU: Status of proposal for public country-by-country reporting

17 Feb - Argentina: Exchanges of country-by-country reports, agreement with United States

17 Feb - Korea: Transfer pricing-related amendments in tax legislation

17 Feb - South Africa: Transfer pricing adjustment upheld; no transfer pricing documentation

16 Feb - France: Taxpayer-favorable court decisions, administrative guidance on intragroup financial transactions

12 Feb - Australia: ATO focus on cross-border financing arrangements

11 Feb - Canada: APA cost-recovery charges cancelled

11 Feb - Germany: Proposed revisions to transfer pricing rules

10 Feb - Rwanda: Transfer pricing rules

4 Feb - Croatia: Arm’s length interest rate on loans between related parties for 2021

3 Feb - Malaysia: Taxpayers now have 14 days to submit transfer pricing documentation when requested by tax authority

2 Feb - India: Transfer pricing measures in Union Budget 2021-2022

2 Feb - Qatar: Transfer pricing declarations required via tax administration portal (Dhareeba)

29 Jan - Australia: Compliance implications, “significant global entity” and “country-by-country reporting entity”

28 Jan - Israel: Characterization of intragroup recharges for stock-based compensation

26 Jan - Thailand: Guidance implementing rules for transfer pricing and related-party transactions

21 Jan - United States: Deductions and credits disallowed, foreign corporation did not file tax returns until after notice of deficiency (U.S. Tax Court)

21 Jan - Belarus: Proposed amendments to transfer pricing control provisions

21 Jan - OECD: Updated guidance on tax treaties (COVID-19)

19 Jan - OECD: Toolkit for developing countries, transfer pricing documentation rules

14 Jan - Russia: First bilateral APA is concluded

13 Jan - Belgium: Transfer pricing audits, new round of information requests

13 Jan - OECD: Compendium of comments on 2020 review of BEPS Action 14

8 Jan - KPMG report: Comments on OECD’s 2020 review of BEPS Action 14

5 Jan - OECD: Consultation meeting on Pillar One and Pillar Two “Blueprints” scheduled for 14-15 January 2021

5 Jan - Malaysia: Transfer pricing measures enacted

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

30 Nov - UK: Transfer pricing remains a significant focus for HMRC

27 Nov - Italy: Transfer pricing documentation guidelines (2020), replaces guidelines from 2010

25 Nov - Australia: Robust comparables, practical considerations on managing the pricing of cross-border arrangements

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

9 Nov - China: Annual advance pricing arrangement (APA) report; statistics for 2019 and future considerations

6 Nov - Lithuania: Updated transfer pricing documentation requirements

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

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

25 Sep - Ireland: EC to appeal General Court’s judgment; tax rulings held not selective tax advantages, arm’s length principle

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

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)

21 Aug - United States-Switzerland: Competent authority arrangement, implementing arbitration process and MAP process

18 Aug - Russia: Tax audit guidelines, verifying reasonableness of expenses for intra-group services

13 Aug - Australia: Guidance on interest-free loans between related parties; thin capitalisation arm’s length debt test

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

3 Aug - United States: Initiative for voluntary resolution of state-level transfer pricing issues (North Carolina)

30 Jul - United States: IRS concept unit on accuracy-related penalties, tax professionals urge caution

30 Jul - Brazil: Comments requested, transfer pricing issues relating to safe-harbour, comparability considerations

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)

15 Jul - Ireland: Tax rulings found not selective tax advantages; arm’s length principle (General Court of EU)

10 Jul - Belgium: Guidance on transfer pricing reporting, BEPS 13 forms

10 Jul - KPMG report: Getting to know the value-chain analysis

9 Jul - Argentina: Revised reporting dates for submitting transfer pricing reports for prior years (COVID-19)

8 Jul - OECD: Corporate tax statistics from country-by-country reporting, activities of multinational enterprises

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)

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)

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)

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

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

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

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

9 Jan - EU: Transfer pricing developments expected in 2020

2 Jan - Luxembourg: Mutual agreement procedures (MAP) regime to resolve transfer pricing, international tax disputes

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

27 Nov - Taiwan: Guidance for taxpayers making a one-time transfer pricing adjustment

21 Nov - United States: Ninth Circuit’s decision upholding section 482 stock-based compensation regulations is final

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

13 Nov - KPMG report: OECD proposal under Pillar Two; addressing tax challenges of digitalisation of the economy

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

28 Oct - United States: APAs cancelled; no transfer pricing adjustments and taxpayer not liable for 40% penalty

25 Oct - KPMG report: Tax implications of “next gen” banking technology; transfer pricing issues with change in operating models

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

30 Sep - OECD: Developing country implementation of transfer pricing documentation rules; comments requested on draft toolkit

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 - Belgium: Pre-filing requests regarding transfer pricing or innovation income deduction, 31 January 2020 deadline

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

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

16 Aug - United States: Ninth Circuit affirms Tax Court; intangible assets and valuation in cost-sharing arrangement

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

1 Aug - United States: KPMG joins amicus brief requesting en banc review by Ninth Circuit (cost-sharing arrangements)

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

23 Jul - Australia: Transfer pricing rules, recharacterizing cross-border financing arrangement as debt or equity

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

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 - Russia: Controlled transactions involving intangibles; profit-split method; mutual agreement procedures

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

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