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27 Jun - UK: Background and implications of delayed implementation of Pillar Two

21 Jun - France: Multinational entity agrees to pay over €1.245 billion to resolve cross-border controversy

21 Jun - Cambodia: Guidance regarding loans between related parties; interest rate and supporting documentation

20 Jun - EU: Report of ECOFIN to European Council on tax issues including Pillar Two, minimum tax, harmful tax practices, preferential tax regimes, non-cooperative jurisdictions

17 Jun - EU: Proposal for EU minimum tax directive; update after ECOFIN Council meeting

17 Jun - India: Updated guidance for mutual agreement procedure (MAP)

16 Jun - United States: Transfer pricing settlement initiative program for corporate taxpayers (New Jersey)

15 Jun - OECD: Comments on tax certainty aspects of Amount A under Pillar One

14 Jun - UK: Implementation of Pillar Two delayed

14 Jun - OECD: Tax transparency in Africa 2022

10 Jun - KPMG report: Comments on tax certainty aspects of Amount A under Pillar One

10 Jun - Luxembourg: Transfer pricing implications of new income tax treaty with UK

9 Jun - OECD: New transfer pricing country profiles for Egypt, Liberia, Saudi Arabia, and Sri Lanka

8 Jun - Peru: Approaching deadline for transfer pricing reports for FY 2021

7 Jun - KPMG report: Country-by-country reporting notifications, requirements per country

7 Jun - United States: Future of consumer and retail—transfer pricing perspective

6 Jun - Poland: Finance Minister’s reply to parliamentary inquiry regarding transfer pricing information

1 Jun - United States: Comments submitted to IRS regarding plans to update MAP and APA guidelines

27 May - OECD: Tax certainty aspects of Amount A under Pillar One; public consultation

25 May - OECD: Comments on regulated financial services exclusion under Amount A of Pillar One

25 May - Hong Kong: Update on corporate tax issues, including transfer pricing documentation

24 May - EU: Status regarding proposal for EU minimum tax directive

23 May - Australia: Labor party wins 2022 election, tax policies include public country-by-country (CbC) reporting

20 May - KPMG report: Comments on regulated financial services exclusion under Amount A of Pillar One

20 May - China: Shenzhen launches first tax and customs collaborative transfer pricing management mechanism

16 May - KPMG report: Public consultation meeting on implementation framework of global minimum tax

11 May - Vietnam: Recommended focus on tax audit and inspection of high-risk industries and areas (transfer pricing)

10 May - Czech Republic: Additional tax assessment based on overall profitability for unrelated-party transactions (court decision)

9 May - Israel: Court decision on business restructuring and deemed transfer of business functions, assets and risks

9 May - Switzerland: Transfer pricing controversy statistics, including effects of COVID-19

6 May - Netherlands: Considerations for companies in scope of Pillar Two rules

6 May - New Zealand: Consultation on implementation of Pillar Two rules

6 May - OECD: Regulated financial services exclusion under Amount A of Pillar One; public consultation

5 May - KPMG report: BEPS 2.0 implementation considerations for Mexico

4 May - Nigeria: Summary of tax transparency reporting developments

4 May - OECD: Tax transparency in Latin America 2022

4 May - Poland: Transfer pricing reporting changes

3 May - OECD: Comments on extractives exclusion under Amount A of Pillar One

3 May - KPMG report: Comments on extractives exclusion under Amount A of Pillar One

3 May - KPMG report: Transfer pricing planning 2.0

3 May - KPMG report: Why operationalizing transfer pricing is more important than ever

3 May - Switzerland: Tax transparency reporting statistics and global minimum tax update

2 May - UK: Transfer pricing statistics (FY 2021)

28 Apr - KPMG report: Transfer pricing and the audit committee agenda, implementation steps

26 Apr - United States: Country-by-country (CbC) report in the transfer pricing risk analysis process (IRS practice unit)

22 Apr - OECD: Comments on draft rules for domestic legislation on scope under Amount A of Pillar One

21 Apr - Kenya: Transfer pricing and other tax-related measures in Finance Bill, 2022

20 Apr - KPMG report: Comments on draft rules for domestic legislation on scope under Amount A of Pillar One

20 Apr - KPMG report: Transfer pricing and the audit committee agenda

20 Apr - Mexico: Considerations for maquiladora transfer pricing strategy, given elimination of APAs

20 Apr - Zimbabwe: Extended deadlines for corporate income tax and transfer pricing returns for 2021

14 Apr - KPMG report: Comments on implementation framework of global minimum tax

14 Apr - KPMG report: Comments in response to UK consultation on global minimum corporate tax

14 Apr - OECD: Comments on implementation framework of global minimum tax

14 Apr - OECD: Extractives exclusion under Amount A of Pillar One; public consultation

12 Apr - Brazil: Update on revisions to transfer pricing rules, steps toward OECD Transfer Pricing Guidelines

12 Apr - Zambia: Country-by-country reporting rules for 2021 tax year

11 Apr - Australia: Tax and transfer pricing implications of IBOR reform

11 Apr - Kenya: Proposed reporting requirements for multinational entities

11 Apr - Latvia: Implications of EU “public” country-by-country reporting for Latvian groups

5 Apr - EU: No agreement on revised proposal for minimum tax directive (ECOFIN Council meeting 5 April 2022)

4 Apr - OECD: Draft rules for domestic legislation on scope under Amount A of Pillar One; comments requested

1 Apr - Thailand: Extended deadline for filing transfer pricing disclosure form for 2020 (COVID-19)

30 Mar - United States: APMA program, APA statistics for 2021 (IRS Announcement 2022-7)

28 Mar - Angola: Transfer pricing implications of updated list of “large taxpayers”

25 Mar - Canada: Mutual agreement procedure (MAP) statistics for 2020

23 Mar - Mexico: Changes introduced by new transfer pricing regulations

22 Mar - Thailand: Determining related parties when same group of shareholders involved

18 Mar - KPMG report: Updated analysis of Pillar Two model rules for 15% global minimum tax following release of commentary

16 Mar - EU: ECOFIN fails to reach agreement on revised minimum tax directive

14 Mar - OECD: Commentary on Pillar Two model rules for domestic implementation of 15% global minimum tax

8 Mar - OECD: Comments on draft model rules for tax base determinations under Pillar One Amount A

7 Mar - Thailand: Revised transfer pricing disclosure form; country-by-country reporting notification and Q&As

4 Mar - KPMG report: Comments on OECD’s draft rules for tax base determinations under Pillar One
Amount A

3 Mar - Estonia: Amendments to transfer pricing regulation

2 Mar - KPMG report: BEPS 2.0 issues and implications for Latin America

1 Mar - Bulgaria: Withholding tax on “fictitious interest” assessed on interest-free loan (CJEU judgment)

28 Feb - Belgium: Tax authorities launch annual round of transfer pricing audits

28 Feb - OECD: Third batch of 2021/2022 updated transfer pricing country profiles

28 Feb - KPMG report: Top concerns for tax leaders on the path forward for BEPS 2.0

28 Feb - Poland: Transfer pricing documentation and financial transactions involving loans

22 Feb - OECD: Comments on draft model rules for nexus and revenue sourcing under Pillar One Amount A

22 Feb - KPMG report: Operational transfer pricing health check

22 Feb - Thailand: Additional country-by-country reporting submission requirements

18 Feb - KPMG report: Initial impressions of draft rules for tax base determinations under Pillar One 
Amount A

18 Feb - OECD: Draft rules for tax base determinations under Amount A of Pillar One; comments requested

17 Feb - KPMG report: Benefits of shared service centers in tax processes such as transfer pricing

17 Feb - South Africa: Draft interpretation note on intragroup loans, new transfer pricing guidance

16 Feb - Denmark: Updated guidance on transfer pricing documentation

15 Feb - Australia: Managing cross-border intercompany financing arrangements (court case)

15 Feb - Botswana: Review of transfer pricing rules

15 Feb - Italy: Guidance concerning transfer pricing documentation, penalty protection regime

14 Feb - Poland: Grant of free-of-charge guarantee treated as “transaction” for transfer pricing purposes (court decision)

11 Feb - Barbados: Rules requiring country-by-country reporting enacted

8 Feb - KPMG report: Transfer pricing in a deals context; risks and opportunities for value creation

7 Feb - Czech Republic: Economic challenges potentially affecting transfer pricing

7 Feb - UAE: Transfer pricing implications with introduction of a corporate income tax regime

6 Feb - KPMG report: Public consultation document on Pillar One—draft model rules for nexus and revenue sourcing

4 Feb - OECD: Public consultation on two-pillar solution launched; first building block under Pillar One released

2 Feb - Nigeria: Transfer pricing outlook for 2022

31 Jan - Mexico: APAs no longer available for maquiladora companies

28 Jan - KPMG report: Transfer pricing documentation viewed as ongoing process, not a short-term project

27 Jan - Cyprus: FAQs on intra-group back-to-back financing transactions

25 Jan - India: A decade of the APA program; why it still makes sense

21 Jan - KPMG report: Implicit guarantees in transfer pricing

20 Jan - Montenegro: New transfer pricing rules

20 Jan - OECD: Transfer pricing guidelines for multinational enterprises and tax administrations

18 Jan - Poland: Individual ruling is not equal to APA (court decision)

14 Jan - Croatia: Corporate profit tax interest rate on loans between related parties

13 Jan - Bahrain: Country-by-country obligations extended to 28 February 2022

12 Jan - Thailand: Extended deadlines for submitting country-by-country reports

11 Jan - UK: Public consultation on implementation of Pillar Two

11 Jan - Azerbaijan: Transfer pricing measures

7 Jan - KPMG report: Common transfer pricing risks and opportunities of M&A transactions

5 Jan - Nigeria: Country-by-country reporting requirements by branches and subsidiaries of foreign MNEs

4 Jan - Malta: Draft transfer pricing rules issued for public consultation

3 Jan - Poland: Safe harbor rate of interest, related-party loans in 2022

22 Dec - EU: Directive to implement Pillar Two is proposed

22 Dec - KPMG report: Initial analysis of Pillar Two model rules for global minimum tax under OECD/G20 Inclusive Framework

22 Dec - Cyprus: Country-by-country report for 2020 is due 31 January 2022

21 Dec - OECD: Schedule for public consultations on two-pillar solution

20 Dec - OECD: Pillar Two model rules for domestic implementation of 15% global minimum tax

17 Dec - Australia: Independent parties would not have agreed to changes to financing arrangement (court decision)

17 Dec - KPMG report: Uneven transfer pricing implications of COVID-19 pandemic

16 Dec - Luxembourg and Ireland: Opinion of CJEU Advocate General regarding tax rulings issued to multinational entities

15 Dec - Australia: Corporate tax transparency data for 2019-2020

14 Dec - KPMG report: Building an effective transfer pricing risk control framework

13 Dec - OECD: New and updated transfer pricing country profiles

10 Dec - Hungary: Considerations for year-end transfer pricing adjustments

2 Dec - Portugal: Guidance concerning advance pricing agreements, transfer pricing documentation

2 Dec - UK: Update on proposed changes regarding transfer pricing documentation

1 Dec - Bahrain: Country-by-country notifications due 31 December 2021

1 Dec - United States and Turkey (Türkiye): Competent Authority Arrangement regarding exchange of country-by-country reports

1 Dec - Zambia: Transfer pricing measures included in 2022 budget

1 Dec - EU: “Public” country-by-country reporting directive published in EU Official Journal

30 Nov - Denmark: Changes to transfer pricing documentation requirements

30 Nov - Germany: Arm's length interest on intercompany loans (court decisions)

29 Nov - KPMG report: EU “public” country-by-country reporting and implications for multinational groups

26 Nov - Australia: Transfer pricing and ATO report on “reportable tax position” schedule

26 Nov - KPMG report: Automating transfer pricing documentation

22 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2020

22 Nov - UK: Transfer pricing items in HMRC annual report and accounts, 2020 to 2021

18 Nov - Australia: Deferral of date for filing (lodging) country-by-country reporting statements

18 Nov - KPMG report: Transfer pricing and factoring

16 Nov - Switzerland: Considerations for transfer pricing year-end adjustments

12 Nov - Netherlands: Legislation addressing mismatches in application of arm’s length principle

11 Nov - EU: European Parliament formally adopts “public” country-by-country reporting

8 Nov - KPMG report: Managing multilateral controversy

3 Nov - Poland: Transfer pricing measures in “Polish Deal” legislation

2 Nov - Dominican Republic: Transfer pricing rules, updated compliance and documentation requirements

2 Nov - United States: Voluntary transfer pricing initiative in Louisiana

1 Nov - China: APA annual report provides statistics for 2020

22 Oct - Ireland: Transfer pricing measures included in Finance Bill 2021

21 Oct - United States: Treasury statement regarding digital services taxes imposed by Austria, France, Italy, Spain, United Kingdom

20 Oct - Bahrain: Updated guidance on mutual agreement procedures

20 Oct - Thailand: Transfer pricing requirements and country-by-country reporting, effective 2021

18 Oct - Cyprus: Arrangement with United States for exchange of country-by-country reports

18 Oct - OECD: Status update on BEPS Action 13 (country-by-country reporting) and Action 14 (mutual agreement procedure)

14 Oct - Austria: Transfer pricing guidelines 2021 are finalized

14 Oct - Serbia: Updated transfer pricing guidance, information for country-by-country report

14 Oct - Vietnam: Guidelines on APA program changes

13 Oct - OECD: G20 finance leaders endorse changes to global tax rules

13 Oct - Czech Republic: Arm’s length price, advertising as a deductible expense (court decision)

11 Oct - UK: Closure notices for transfer pricing enquiries, despite ongoing diverted profits tax review (First-tier Tribunal)

9 Oct - KPMG report: OECD/G20 Inclusive Framework agreement on BEPS 2.0

8 Oct - OECD: Agreement for global minimum tax, to resolve international taxation of digital economy

7 Oct - Thailand: New requirements for transfer pricing and Local file documentation

4 Oct - KPMG report: Country-by-country reporting, notification requirements per country

30 Sep - KPMG report: LIBOR transition, transfer pricing considerations of intercompany financial arrangements

29 Sep - Jordan: Instructions for implementing transfer pricing regime include documentation requirements

29 Sep - KPMG report: Managing transfer pricing and customs risks of cross-border transactions

28 Sep - EU: Update on "public" country-by-country reporting

27 Sep - Switzerland: Arm’s length price and transfer pricing implications of financial guarantees

22 Sep - Netherlands: Proposal to address mismatches in non-arm’s length transfer pricing

20 Sep - Poland: “Executed tax strategy” reporting requirements, include transfer pricing information

16 Sep - Peru: Approaching deadline for secondary filing by U.S. multinationals of FY 2020 country-by-country reports

14 Sep - Mexico: Transfer pricing proposals in economic package for 2022

14 Sep - Namibia: Transfer pricing adjustments when transaction not at arm’s length

13 Sep - Singapore: New release of transfer pricing guidelines

13 Sep - Taiwan: Customs requirements when making one-time transfer pricing adjustments

3 Sep - Botswana: Threshold for preparing and filing transfer pricing documentation

31 Aug - Germany: New administrative guidelines for transfer pricing

25 Aug - KPMG report: Digitalization driving new operating models for financial services industry; transfer pricing considerations

17 Aug - India: Tax relief, computation when book profit increase due to APA or secondary adjustments

11 Aug - Czech Republic: Transfer pricing issues remain under scrutiny

9 Aug - Hong Kong: Guidance addressing transfer pricing issues (COVID-19)

3 Aug - OECD: Transfer pricing country profiles; updated for financial transactions and permanent establishments

2 Aug - China: Simplified procedure for unilateral APAs

29 Jul - Poland: Transfer pricing measures in proposed tax legislation

20 Jul - Iceland: Penalty provisions introduced for transfer pricing documentation noncompliance

19 Jul - Sri Lanka: Transfer pricing rules, documentation requirements

16 Jul - United States: Section 482 adjustments for cost-sharing agreements with reverse claw-back provisions (Chief Counsel legal advice memo)

15 Jul - Bahrain: Country-by-country reporting and notification obligations

15 Jul - Oman: Clarification of suspension of country-by-country reporting

14 Jul - Netherlands: Formal investigation of tax rulings, transfer pricing issues (EU General Court)

13 Jul - Kenya: Country-by-country reporting measures enacted in Finance Act, 2021

13 Jul - Russia: Transfer pricing audits, focus on pre-audit analysis

10 Jul - G20 finance ministers conclude meeting with agreement for global minimum tax, other measures

8 Jul - Oman: Country-by-country reporting is suspended

6 Jul - Madagascar: Transfer pricing documentation requirements

2 Jul - Canada: Guidance on obtaining Competent Authority assistance, MAP requests and transfer pricing adjustments

2 Jul - KPMG report: OECD/G20 Inclusive Framework agreement on BEPS 2.0

1 Jul - OECD: Statement of Inclusive Framework on two-pillar solution addressing tax challenges of digital economy

30 Jun - Germany: Provisions amending arm’s length principle, transfer pricing

29 Jun - Singapore: GST implications of common transfer pricing adjustments

29 Jun - South Africa: Transfer pricing adjustments and implications for VAT purposes

28 Jun - Jordan: Transfer pricing regulations are introduced

25 Jun - Azerbaijan: Update on country-by-country reporting

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 (Türkiye): Country-by-country reporting, automatic exchanges under CbC MCAA

22 Dec - Turkey (Türkiye): 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 (Türkiye): 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 (Türkiye): 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 One 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