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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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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

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

July 2019

31 Jul - Argentina: Extended compliance deadlines for transfer pricing

29 Jul - EU: Statistics of APAs and MAPs for 2018

29 Jul - KPMG report: Evaluating transfer pricing as part of risk management

25 Jul - France: Digital services tax (3%) is enacted

25 Jul - New Zealand: Update on digital services tax consultation

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

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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