Transfer Pricing
Transfer Pricing
TaxNewsFlash-Transfer Pricing — KPMG's reports of transfer pricing developments from across the globe
Transfer Pricing Review (2015)
Transfer Pricing Review provides transfer pricing information for almost 100 countries, including documentation requirements, deadlines, transfer pricing methods, penalties, special considerations, advance pricing agreements, and competent authority matters.
TaxNewsFlash-Transfer Pricing
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Prior Editions
Prior editions of TaxNewsFlash-Transfer Pricing (from 2014) are listed below, and are searchable by key words.
For a copy of a prior edition, send an email to US-KPMGWNT@kpmg.com with (1) date and (2) title. A copy will be sent to you as soon as possible.
2014 Editions [PDF 957 KB]
Recent articles
May 2018
11 May - United States: New IRS template for requesting advance pricing agreement (APA)
10 May - Taiwan: Country-by-country reporting for 2017 corporate income tax return
10 May - OECD: Comments requested on future revisions, Transfer Pricing Guidelines
1 May - Australia: ATO's final draft, Australian Local file requirements for 2018 tax years
April 2018
27 Apr - Hong Kong: Transfer pricing amendments to the “BEPS bill”
25 Apr - India: Arm’s length price of related party not controlling on taxpayer
19 Apr - Denmark: Transfer pricing documentation; court applies contemporaneous preparation rule
18 Apr - Poland: Transfer pricing forum considers benchmarking studies, simplified APA procedure
10 Apr - OECD: Transfer pricing “country profiles” add new profiles for 14 countries
5 Apr - Singapore: Cost plus mark-up basis of assessment for service companies
March 2018
30 Mar - United States: APMA program, APA statistics for 2017
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
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
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 - 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
February 2018
28 Feb - Singapore: Expanded transfer pricing rules
27 Feb - India: APAs on treatment of advertising, marketing, and promotion expenses
26 Feb - Kazakhstan: Transfer pricing documentation includes country-by-country reporting
26 Feb - Lithuania: New transfer pricing documentation rules in draft order
23 Feb - UK: Updated MAP statement of practice and HMRC associated guidance
22 Feb - Italy: Draft transfer pricing regulations released for public consultation
13 Feb - Costa Rica: Details on country-by-country reporting requirements
13 Feb - Norway: Guidelines for mutual agreement procedure (MAP)
13 Feb - Poland: Guidance on preparation of transfer pricing documentation
9 Feb - Croatia: Determining the interest rate on related-party loans
8 Feb - OECD: Update on BEPS implementation, country-by-country reporting
6 Feb - Malaysia: Revisions, updates to APA rules and MAP guidelines
2 Feb - India: Transfer pricing proposals in 2018 budget, country-by-country reporting clarifications
January 2018
30 Jan - Jamaica: Transfer pricing declaration, file with income tax return
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
18 Jan - United States: Updated FAQs, information about country-by-country reporting
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
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”
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 - 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 - Greece: Country-by-country reporting update
9 Oct - India: Proposed country-by-country reporting, Master file rules
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
2 Oct - KPMG report: Common-sense transfer pricing compliance in a BEPS world
September 2017
29 Sep - Japan: Tax agency’s Q&A guidance on mutual agreement procedure (MAP)
26 Sep - Argentina: Country-by-country reporting rules
20 Sep - United States: IRS updates country-by-country reporting guidance
20 Sep - OECD: IT guidelines for country-by-country reporting exchanges
18 Sep - KPMG report: Discussion draft, BEPS Action 10 revised guidance on profit splits
18 Sep - United States: LB&I practice units about transfer pricing issues
15 Sep - UK: Effects of diverted profits tax on transfer pricing adjustments; 90% increase
14 Sep - Lithuania: Country-by-country reporting rules
13 Sep - Spain: New form for reporting related-party transactions, or transactions involving “tax havens”
12 Sep - Ireland: Transfer pricing included in recommendations for corporation tax
6 Sep - OECD: New guidance on country-by-country reporting (BEPS Action 13)
5 Sep - Denmark: Annual reporting on transfer pricing adjustments
August 2017
30 Aug - United States: List of countries for country-by-country reporting data exchanges
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
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
July 2017
28 Jul - Asia Pacific: Transfer pricing review, third quarter 2017
28 Jul - India: “Location savings” not sole basis for arm’s length price
26 Jul - United States: Cancellation of APAs by IRS, abuse of discretion
20 Jul - Czech Republic: Legislation for implementing country-by-country reporting advances
18 Jul - OECD: Additional guidance for country-by-country reporting (BEPS Action 13)
13 Jul - Mexico: Negotiating APAs, “fast track” for maquila companies
13 Jul - Vietnam: Tax and transfer pricing implications of technology transfers, new law
12 Jul - Malaysia: Updated guidelines for transfer pricing
11 Jul - Singapore: Draft transfer pricing legislation
10 Jul - OECD: Updates to transfer pricing guidelines for multinational enterprises
10 Jul - Asia Pacific: Country-by-country reporting; implementation issues
7 Jul - EU: European Parliament adopts report on proposal for “public” country-by-country reporting
7 Jul - Asia Pacific: Survey of country-by-country reporting in 15 countries
7 Jul - United States: IRS provides FAQs on country-by-country reporting
5 Jul - OECD: Comments on BEPS discussion draft; guidance on hard-to-value intangibles
5 Jul - Japan: Retroactive transfer price adjustments, from customs valuation perspective
5 Jul - Nigeria: Overviews of transfer pricing regime, audit process
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: BEPS discussion drafts, attribution of profits to permanent establishments and transactional profit splits
21 Jun - EU: Proposed mandatory disclosure of reportable tax planning cross-border arrangements
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
12 Jun - Costa Rica: Time for filing transfer pricing returns is extended
9 Jun - India: Revised “safe harbour rules” focus on transfer pricing disputes
7 Jun - Azerbaijan: Transfer pricing rules introduced; effective for 2017
7 Jun - India: Evaluating advertising and marketing promotion expenses as international transaction
6 Jun - Colombia: Transfer pricing regime, rules for controlled foreign corporations
6 Jun - Hungary: Country-by-country reporting approved by parliament
May 2017
30 May - OECD: Initial impressions about discussion draft, hard-to-value intangibles
30 May - Pakistan: Transfer pricing audit, penalty provisions in budget 2017
30 May - Turkey: Transfer pricing provisions and country-by-country reporting rules
26 May - KPMG report: Potential ripple effects of BEPS reforms, beyond tax issues
25 May - India: Expense reimbursements not taxable; transfer pricing study showed no profit element
24 May - Israel: Update on status of country-by-country reporting
23 May - OECD: Discussion draft, guidance on hard-to-value intangibles
22 May - India: Excluding cost reimbursements from related parties (without mark-up) from operating costs
22 May - India: Export commission paid to related party not a royalty; transfer pricing adjustment rejected
18 May - Australia: Related-party financing arrangements, analysis
18 May - France: Country-by-country reporting notification and filing requirements
16 May - Australia: ATO draft guidance on related-party financing arrangements
16 May - Czech Republic: Update on transfer pricing assessments
11 May - Korea: Update on country-by-country reporting, transfer pricing rules
9 May - India: Convertible loans, loan guarantees for foreign related parties
8 May - Norway: Proposed earnings stripping rule changes; interest paid to related parties
8 May - UK: Group ratio method and related parties, possible corporate
interest restriction
5 May - India: Report of APA statistics
April 2017
27 Apr - United States: Government appeals Tax Court’s decision, section 482 adjustment
25 Apr - Costa Rica: Master file, Local file and other recordkeeping requirements
23 Apr - Russia: Updated country-by-country reporting, transfer pricing documentation proposals
21 Apr - Australia: Transfer pricing implications of related-party loans; appellate court decision
21 Apr - Netherlands: Measures on exchanging country-by-country reports
20 Apr - UN: Updated transfer pricing publication, developing countries
19 Apr - Australia: Country-by-country reporting, Local and Master files detailed design
14 Apr - Mexico: Final rules, annual information returns of related parties
10 Apr - UK: Transfer pricing dispute resolution, new remedies reflecting BEPS recommendations
6 Apr - OECD: Updated country-by-country guidance, under BEPS Action 13
5 Apr - Australia: Simplified transfer pricing record-keeping options
5 Apr - India: Transfer pricing adjustments for intra-group services
3 Apr - Germany: Discussion draft, transfer pricing documentation requirements
3 Apr - United States: Transfer pricing documentation deadlines for 2017
March 2017
30 Mar - China: Guidance integrating BEPS, transfer pricing audit practices
30 Mar - India: Five APAs signed, transactions involving management cross-charges
29 Mar - Poland: Transfer pricing, country-by-country reporting exchange of information
27 Mar - US: APMA program, APA statistics for 2016
15 Mar - India: Related-party relationship upheld, sales constituted 20% of total sales
15 Mar - Serbia: Arm’s length interest rates for related-party financing
14 Mar - Australia: Considering how CbC reporting may affect globally mobile workforce
13 Mar - Australia: ATO guidance for the Australian “Local file”
10 Mar - Italy: Implementing decree, country-by-country reporting rules
8 Mar - Sweden: Guidance on country-by-country reporting notification, filing process
3 Mar - New Zealand: Transfer pricing, BEPS measures released for consultation
2 Mar - Cyprus: Back-to-back loans to require transfer pricing study
1 Mar - Vietnam: Country-by-country reporting part of expanded transfer pricing documentation guidelines
February 2017
28 Feb - Argentina: Court characterizes intercompany loan as capital contribution
28 Feb - India: Profits attributed to permanent establishment; transfer pricing study rejected
28 Feb - Poland: Significant increase in revenue collections, following transfer pricing audits
24 Feb - United States: Draft instructions for Form 8975, Country-by-Country Report
23 Feb - India: Resale price method, distributor adds no value to goods
23 Feb - South Africa: Transfer pricing measures in 2017 budget
22 Feb - Hong Kong: Transfer pricing in budget speech; proposed legislation expected
21 Feb - OECD: Comments on helping developing countries, lack of comparables for transfer pricing analyses
17 Feb - Canada: Country-by-country reporting form is released
14 Feb - France: Country-by-country reporting form
10 Feb - Botswana: Introduction of transfer pricing legislation under consideration
10 Feb - UK: HMRC guidance on transfer pricing aspects of cash pooling
9 Feb - Hong Kong: Update on introduction of transfer pricing rules
9 Feb - India: Update on APAs
3 Feb - India: Transfer pricing proposals in budget 2017
1 Feb - OECD: Peer review documents, assessment of BEPS minimum standards (Actions 13 and 5)
January 2017
27 Jan - UK: Revised HMRC guidance, no transfer pricing discussions outside APAs
26 Jan - Indonesia: New transfer pricing requirements include country-by-country reporting
25 Jan - OECD: Helping developing countries with comparables for transfer pricing analyses
24 Jan - Belgium: Transfer pricing documentation
24 Jan - Nigeria: Transfer pricing forms for 2017
20 Jan - Australia: ATO guidance on related-party marketing hubs
19 Jan - India: Loss-making companies as comparables
19 Jan - United States: IRS guidance on country-by-country report filing process
16 Jan - Australia: Q&As on country-by-country reporting
16 Jan - Singapore: Updated transfer pricing guidelines released
14 Jan - Peru: Transfer pricing legislation reflects OECD recommendations
12 Jan - United States: Draft Form 8975 for country-by-country reporting
11 Jan - Brazil: Certain Austrian holding companies identified as “privileged tax regime”
10 Jan - Cyprus: Decree adopting country-by-country reporting; notification extended to October 2017
6 Jan - Malaysia: Final rules on annual country-by-country reporting
5 Jan - Dominican Republic: Update of “white list” countries, transfer pricing implications
4 Jan - United States: IRS practice unit, section 367(d) transactions and cost sharing arrangments
3 Jan - Brazil: Country-by-country reporting rules
3 Jan - Chile: Country-by-country reporting required in new transfer pricing affidavit
3 Jan - Korea: Country-by-country reporting, transfer pricing reporting proposed changes
December 2016
29 Dec - Luxembourg: Revisions to transfer pricing circulars; intra-group financing transactions
28 Dec - Luxembourg: Country-by-country reporting, notification procedure
23 Dec - Ireland: EC state aid investigation of transfer pricing rulings
22 Dec - Dominican Republic: Transfer pricing compliance; free trade zone waivers
15 Dec - Slovakia: Country-by-country reporting introduced in new government bill
13 Dec - France: Country-by-country public financial reporting held unconstitutional
9 Dec - Denmark: Country-by-country notification requirements
7 Dec - Australia: Country-by-country reporting Q&As
5 Dec - Norway: Country-by-country reporting pursuant to BEPS Action 13
5 Dec - OECD: BEPS guidance on country-by-country reporting, country-specific information on implementation
5 Dec - OECD: Mutual agreement procedure (MAP) statistics for 2015
2 Dec - Belgium: Transfer pricing documentation forms are published
November 2016
30 Nov - Czech Republic: High court disallows loss for “toll manufacturer”
30 Nov - Finland: Country-by-country reporting, Master file, Local file requirements
28 Nov - Luxembourg: Pending draft law, implications for transfer pricing studies
23 Nov - France: Reduced threshold, eligibility for abridged transfer pricing documentation
22 Nov - U.S. Tax Court: Taxpayer entitled to full DRD, accounts receivable under section 965
22 Nov - Netherlands: Country-by-country reporting, 2016 notification deadline is extended
21 Nov - India: Transfer pricing method applies uniformly to all international transactions
18 Nov - India: Update on MAP, bilateral APA case resolution with United States
17 Nov - Brazil: Initial BEPS guidance on dispute resolution; CbC consultation
11 Nov - UK: Updated HMRC guidance on APAs
2 Nov - South Africa: Additional transfer pricing documentation rules are finalized
1 Nov - OECD: Taxpayer questionnaire, input into MAP process
October 2016
28 Oct - Hong Kong: Consultation on formal transfer pricing regime
28 Oct - OECD: Automatic exchange of tax information agreement, signed by Cook Islands
25 Oct - Channel Islands: Country-by-country reporting, draft regulations in Jersey
24 Oct - Singapore: Country-by-country reporting guide
21 Oct - Ireland: Irish Revenue updates FAQs on country-by-country reporting
21 Oct - OECD: Five jurisdictions agree to automatic exchange of country-by-country reports
21 Oct - Vietnam: Draft decree to implement transfer pricing standards, BEPS recommendations
20 Oct - Ireland: Transfer pricing considerations of centralised procurement strategies
18 Oct - China: New APA administrative guidelines, effective December 2016
18 Oct - India: Implications of APA on pre-rollback transactions
18 Oct - India: Transfer pricing not applicable to transactions with foreign branch office
14 Oct - US: IRS position on unilateral APA applications involving maquiladoras
14 Oct - Luxembourg: Budget proposals, to transpose arm’s length principle, transfer pricing analysis
14 Oct - UK: Practical issues that businesses may face concerning country-by-country reporting
13 Oct - Australia: Involving human resources, mobility professionals in country-by-country reporting
11 Oct - India: Arm's length interest rate on related-party borrowings
11 Oct - India: Effects of customs duty, air freight, currency fluctuation adjustments on arm’s length price
10 Oct - France: Decree implementing country-by-country reporting
September 2016
28 Sep - Channel Islands: Country-by-country reporting, consultation in Guernsey
28 Sep - OECD: Public consultation on BEPS-related transfer pricing matters, 11-12 October
28 Sep - Sweden: Country-by-country reporting provisions in budget bill for 2017
27 Sep - Australia: Country-by-country reporting exemption guidance
23 Sep - United States: Guidance for IRS agents, applying arm’s length standard
20 Sep - India: Treaty with South Korea would allow bilateral APAs, MAPs
20 Sep - Denmark: New executive order on country-by-country reporting
16 Sep - Russia: Country-by-country reporting requirements, transfer pricing documentation
14 Sep - Costa Rica: Transfer pricing return, procedures are finalized
14 Sep - Pakistan: Automatic exchange of country-by-country reports
13 Sep - United States: EC state aid investigations show need for tax reform
9 Sep - UK: Public country-by-country reporting, amendment to Finance Bill 2016
2 Sep - India: Effects of arm’s length price adjustment on taxable income
1 Sep - Brazil: Automatic exchange of country-by-country reports
August 2016
31 Aug - Germany: Transfer pricing rules requiring adjustment on cross-border arrangements referred to CJEU
31 Aug - Poland: Tax authorities continue to focus on transfer pricing
30 Aug - Ireland: EC state aid investigation, “illegal tax benefits” to multinational company of €13 billion
24 Aug - Poland: Cash-pooling arrangements are loans, transfer pricing documentation rules apply
24 Aug - Poland: Increased number of transfer pricing audits, increased assessments
24 Aug - OECD: Comments on proposed amendments, OECD Transfer Pricing Guidelines
22 Aug - Liechtenstein: Automatic exchanges of CRS, country-by-country reporting
19 Aug - Asia Pacific: Transfer pricing review (2016 supplement)
18 Aug - Czech Republic: Automatic exchange of APAs, country-by-country reporting proposals
16 Aug - India: Application of Berry ratio, transfer pricing methodology
16 Aug - Israel: Country-by-country reporting, transfer pricing documentation in budget plan
16 Aug - Hong Kong: Management fee, head office recharge arrangements under scrutiny
16 Aug - Turkey: New transfer pricing rules enacted, aligned with OECD guidelines
15 Aug - Greece: Transfer pricing documentation deadline is extended
11 Aug - Nigeria: Country-by-country reporting, implementation moves forward
9 Aug - Canada: Discussion, observations about country-by-country reporting proposal
9 Aug - Germany: Loan guarantees by German parent company, for foreign subsidiaries
8 Aug - Asia Pacific: Country-by-country reporting, status update for region
8 Aug - EU: Country-by-country reporting—an EU perspective
5 Aug - Australia: Review of transfer pricing developments since 2012; plans for more changes
5 Aug - Luxembourg: Draft law for country-by-country reporting submitted to Parliament
5 Aug - India: No transfer pricing referral, when taxpayer claims no “international transactions”
5 Aug - India: Taxpayer allowed to change from TNMM to CUP during proceedings
3 Aug - Canada: Country-by-country reporting requirements in draft legislative proposals
1 Aug - Korea: Revised legislation, transfer pricing and country-by-country reporting rules
July 2016
29 Jul - Mexico: Transfer pricing measures in tax legislation
26 Jul - India: Transfer Pricing Officer’s authority to examine arm’s length price
25 Jul - Austria: New transfer pricing documentation, country-by-country rules effective for 2016
25 Jul - OECD: Report on status of BEPS project
21 Jul - Czech Republic: Regional courts reject basis for transfer pricing assessments
18 Jul - U.S. Tax Court: Newspaper’s motion to intervene in cost-sharing arrangement case held in abeyance
15 Jul - Hong Kong: Transfer pricing and offshore tax regimes
14 Jul - India: Taxpayer must have opportunity to cross-examine comparable companies’ personnel
13 Jul - China: Transfer pricing documentation, related-party reporting guidance from BEPS project
11 Jul - Hong Kong: BEPS participation, recommendations pending government action
8 Jul - India: Valuation of intangibles; only future projections, no hindsight allowed
7 Jul - OECD: Discussion draft under BEPS Actions 8-10, profit split guidance
7 Jul - OECD: Discussion draft under BEPS Action 7, profits attributed to
permanent establishments
6 Jul - Hong Kong: Transfer pricing and BEPS considerations—intangible property and R&D activities
6 Jul - Sweden: Revising an agreement’s conditions to arm’s length terms
5 Jul - Belgium: Country-by-country reporting, transfer pricing documentation; new law is published
5 Jul - India: No transfer pricing adjustment; license agreement with U.S. company
4 Jul - Japan: Guidance under new transfer pricing documentation rules
4 Jul - OECD: BEPS discussion drafts include revised guidance on profit splits
4 Jul - OECD: Comments invited on revised transfer pricing guidelines
1 Jul - Germany: Country-by-country reporting, BEPS items in draft bill
June 2016
29 Jun - United States: Initial description of country-by-country reporting final regulations
29 Jun - OECD: Guidance on implementation of country-by-country reporting
29 Jun - United States: Country-by-country reporting, final regulations (text)
27 Jun - India: Prior MAP not justification for proposed transfer pricing adjustment
24 Jun - Singapore: Country-by-country reporting
22 Jun - India: No transfer pricing adjustment warranted for corporate guarantee
20 Jun - Finland: Transfer pricing documentation, country-by-country reporting draft legislation
17 Jun - India: Inconsistent positions of tax authorities; same transaction, different years
16 Jun - OECD: Webcast discussions about BEPS, tax transparency
15 Jun - OECD: BEPS amendments incorporated into Transfer Pricing Guidelines
13 Jun - Luxembourg: Tax ruling in EC state aid investigation is published
10 Jun - Costa Rica: Draft rules for annual transfer pricing return
9 Jun - US Tax Court: Medical devices and leads transfer pricing issues
3 Jun - UK: Proposed secondary adjustment rule, for transfer pricing provisions
May 2016
25 May - Australia: Country-by-country, final Local files released
25 May - Norway: Transfer pricing documentation, country-by-country reporting included in political agreement
23 May - US: Senators again express concerns about EC state-aid investigations
23 May - Denmark: Transfer pricing adjustment statistics, trends and
forecast
20 May - EU: “State aid” and transfer pricing rulings
19 May - Denmark: New transfer pricing documentation requirements
19 May - Austria: Proposed legislation, transfer pricing documentation and country-by-country reporting
16 May - Belgium: Draft law, country-by-country reporting and transfer pricing documentation requirements
13 May - Czech Republic: Transfer pricing examination trends
13 May - Norway: Proposed legislation to implement country-by-country reporting rules
12 May - OECD: Canada, Iceland, India, Israel, New Zealand, China advance country-by-country reporting
12 May - US: IRS practice unit, taxpayer’s affirmative use of section 482
11 May - Peru: New forms for transfer pricing declarations
10 May - Hungary: Transfer pricing measures in tax legislative proposals
10 May - India: No transfer pricing adjustment for advertising, marketing, and promotion
April 2016
28 Apr - India: APA for earlier year may apply, determining “tested party”
27 Apr - WCO: Agreement on transfer pricing, customs valuation
27 Apr - Japan: Country-by-country reporting requirements
26 Apr - Switzerland: Country-by-country reporting, implementing legislation advances
20 Apr - Canada: Procedures for exchange of tax rulings under BEPS rules
20 Apr - Bermuda: Country-by-country reports, automatic exchange agreement signed
14 Apr - India: Benchmarking the arm’s length interest rate on related-party debt
13 Apr - Canada: No cost-based transfer price reduction, government assistance
12 Apr - South Africa: Draft regulations, country-by-country reporting
12 Apr - EU: “Public” country-by-country reporting for multinational enterprises advances
11 Apr - India: Factors to be used in selecting comparables
6 Apr - US: IRS practice unit examines three requirements to apply section 482
4 Apr - Canada: Country-by-country reporting in 2016
1 Apr - Italy: New guidelines for international tax rulings and APAs
March 2016
31 Mar - US: APMA program, APA statistics for 2015
31 Mar - Korea: Master file and local file templates are released
28 Mar - UK: BEPS items included Finance (No. 2) Bill 2016
24 Mar - OECD: Treaty benefits for non-CIV funds; BEPS follow-up consultation
23 Mar - Canada: Country-by-country reporting, transfer pricing proposals in 2016 federal budget
23 Mar - EU: Draft proposal on “public” country-by-country reporting
22 Mar - India: No aggregation of transactions for benchmarking in “unusual” circumstances
22 Mar - OECD: Standardized electronic format for exchanging country-by-country reports
21 Mar - US: IRS “practice unit” on inbound resale price method, routine distributor
18 Mar - Turkey: Draft communiqué on transfer pricing documentation, country-by-country reporting
16 Mar - Indonesia: FAQs on transfer pricing
14 Mar - India: New guidelines for transfer pricing referrals
14 Mar - US: IRS “practice unit” on interest expense limitation under section 163(j), related-party debt
11 Mar - UK: Preparing for country-by-country reporting
10 Mar - Nigeria: Transfer pricing comparable data constraint—issues, implications
9 Mar - Australia: Costs of non-compliance with country-by-country reporting requirements
8 Mar - EU: Automatic exchange of country-by-country reporting by multinational companies
Mar 8 - India: Brand-promotion expenses not “international transaction” for arm’s length standard
7 Mar - US: Treasury responds to Congress, EU state-aid “tax ruling” investigations
7 Mar - US: IRS "practice unit," residual profit split method, outbound
4 Mar - Poland: Enhanced tax audit focus on transfer pricing
4 Mar - US: IRS “practice unit,” transfer pricing documentation by outbound taxpayers
3 Mar - UK: Final country-by-country reporting regulations
3 Mar - EU: State-aid investigations of “tax rulings,” response to U.S. concerns
2 Mar - Dominican Republic: Amount triggering transfer pricing regime, related-party transactions (2016)
1 Mar - India: Country-by-country reporting, transfer pricing documentation rules in budget 2016
February 2016
29 Feb - US: Transfer pricing adjustments involving consolidated group members
22 Feb - India: Functional comparability of taxpayer’s business segments
22 Feb - New Zealand: Exchange of transfer pricing rulings
17 Feb - EU: Double taxation, dispute resolution mechanisms consultation
16 Feb - India: Payment of 2% on sales considered at arm’s length
16 Feb - India: Valuing imports from a related party for customs purposes
16 Feb - Romania: New rules, standards for transfer pricing documentation
12 Feb - Belgium: New wave of transfer pricing audits
11 Feb - US: Treasury letter to EC on state aid investigations
11 Feb - Australia: Consultation on BEPS-related transfer pricing recommendations
4 Feb - South Africa: Mandatory transfer pricing documentation is proposed
4 Feb - US: IRS “practice unit” guidance on intercompany interest rates, cost sharing arrangements
3 Feb - Singapore: GST implications of transfer pricing adjustments
2 Feb - Nigeria: Country-by-country reporting update
1 Feb - US: Bilateral APAs with India being accepted, beginning 16 February
1 Feb - India: Bilateral APAs with UK, concerning management charges, brand royalty
January 2016
27 Jan - India: Cross-border share reorganisation, transfer pricing rules not triggered
27 Jan - OECD: Agreement signed for exchange of country-by-country reporting information
26 Jan - OECD: Countries to sign country-by-country implementation agreement
25 Jan - Singapore: New, updated transfer pricing guidance
20 Jan - France: Country-by-country reporting, transfer pricing declaration
15 Jan - Brazil: Revised position of tax authorities, cost-reimbursement arrangements
15 Jan - US: Senate Finance members urge Treasury intensify efforts, EU state aid investigations
13 Jan - Australia: Prepare now for country-by-country reporting
12 Jan - Finland: Transfer pricing documentation rules, country-by-country reporting proposal
6 Jan - Brazil: Dutch holding companies again identified as “privileged tax regimes”
6 Jan - Argentina: “White list” countries for 2016; transfer pricing implications
5 Jan - Norway: Country-by-country reporting proposal, public consultation
5 Jan - Netherlands: New transfer pricing documentation rules enacted; country-by-country reporting
4 Jan - Korea: Master file and local file; “full” transfer pricing reporting
2015 Articles
December 2015
29 Dec - Croatia: Related-party loans, interest rate increase for 2016
29 Dec - Poland: Ministry of Finance focus on transfer pricing
23 Dec - US: KPMG report, proposed regulations on country-by-country reporting
23 Dec - Italy: Country-by-country reporting approved in 2016 budget law
22 Dec - Denmark: Country-by-country reporting for 2016
22 Dec - Ireland: Country-by-country legislation is enacted
21 Dec - US proposed country-by-country reporting regulations
18 Dec - Australia: Country-by-country reporting guidelines
17 Dec - India: Marketing intangibles by licensed manufacturer, no transfer pricing adjustment
15 Dec - Jamaica: Transfer pricing rules require reporting of related-party transactions (2015)
15 Dec - Japan: Transfer pricing documentation rules, based on BEPS recommendations
14 Dec - India: Corporate guarantee made for subsidiary, transfer pricing adjustment rejected
14 Dec - Mexico: Reminder of expanded transfer pricing disclosures for 2016
11 Dec - Korea: Agreement with India, suspending tax collection during pending MAP
8 Dec - EU: Directive on automatic exchange of tax rulings, APAs
3 Dec - Luxembourg: EC investigation of tax rulings, issued to US multinational
November 2015
30 Nov - Netherlands: Dutch government appeals EC decision, concerning APA
25 Nov - KPMG's Transfer Pricing Review (2015)
18 Nov - Nigeria: Implications of BEPS proposals
16 Nov - Netherlands: Advance tax rulings; changes possible before April 2016
11 Nov - India: No transfer pricing adjustment when tax avoidance not possible
10 Nov - UK: Changes to interest deductibility rules, implications for transfer pricing
9 Nov - France: Status of transfer pricing documentation, country-by-country reporting
5 Nov - Australia: Are investment entities excluded from “group” for country-by-country reporting?
5 Nov - Poland: Expanded transfer pricing, country-by-country reporting enacted
5 Nov - US: IRS practice unit, licensing of intangible property to foreign subsidiary
October 2015
29 Oct - India: No “notional interest” on related-party outstanding receivables
27 Oct - Australia: Transfer pricing, intercompany financing transactions
26 Oct - France: Recent trends in transfer pricing, survey
26 Oct - Hungary: Implementing transfer pricing-related BEPS actions
26 Oct - Singapore: Transfer pricing documentation, due 30 November
21 Oct - India: Transfer pricing guidance, case selection and multiple-year range
21 Oct - EU: “Tax rulings” in Luxembourg, Netherlands deemed illegal state aid
19 Oct - India: Valuation issues, fixed assets and cost sharing arrangement
13 Oct - OECD: Status of BEPS Action 13 local implementation, transfer pricing
9 Oct - Australia: BEPS and transfer pricing; comparison to Australian approach
6 Oct - EU: Automatic exchange of information, cross-border tax rulings and APAs
2 Oct - India: Comparables rejected; no add-back of transfer pricing adjustment
September 2015
24 Sep - Italy: Five-year tax agreement; treatment of cross-border items, transfer pricing
23 Sep - Denmark: Country-by-country reporting, documentation proposed
22 Sep - Korea: Related-party marketing fees not subject to customs duty
18 Sep - China: Transfer pricing discussion draft; BEPS influence
18 Sep - Mexico: Transfer pricing, country-by-country reporting proposals
17 Sep - Poland: Update on transfer pricing legislation
16 Sep - Netherlands: “Country-by-country” reporting, documentation proposed for 2016
16 Sep - Australia: Country-by-country bill introduced
15 Sep - Australia: Transfer pricing, changing nature of tax controversy
15 Sep - US: Regulations coordinating rules under sections 367, 482
14 Sep - France: Transfer pricing assessments; withholding tax relief for repatriated profits
8 Sep - India: No related-party relationship, despite substantial single-party purchases
8 Sep - India: Profit split method upheld, activities were “inextricably linked”
3 Sep - Nigeria: Safe harbour in the transfer pricing regulations?
August 2015
30 Aug - India: Voice-call centers; not all IT-enabled services are comparable
28 Aug - US: IRS training guides on foreign-to-foreign transactions, transfer pricing rules
26 Aug - Ecuador: Percentages for deducting royalties, other payments to related parties
20 Aug - Korea: Law to implement BEPS-related transfer pricing requirements
18 Aug - US: Explanation of competent authority revenue procedure
18 Aug - US: Explanation of new APA guidance
12 Aug - Australia: Country-by-country reporting update
12 Aug - US: New guidance for Competent Authority assistance
12 Aug - US: New guidance under APA program
10 Aug - Australia: Renewed focus on arm’s length behaviours
10 Aug - China: Cross-border payments to foreign related parties
7 Aug - Australia: Proposed CbC, transfer pricing documentation requirements
7 Aug - US: Future cost-sharing regulations, controlled transactions involving partnerships
6 Aug - India: First APA rollback signed; concerns U.S. company
July 2015
31 Jul - Hong Kong: Focus on head office, service company recharges
27 Jul - US: Tax Court finds cost-sharing regulations invalid
20 Jul - India: Interest on funds advanced to related entity
17 Jul - India: MAP with Japan; manufacturer’s transfer pricing resolved
15 Jul - India: Multiple-year data allowed, transfer pricing rules satisfied
8 Jul - Poland: Draft transfer pricing regulations, documentation and reporting requirements
7 Jul - China: Guidance on cost sharing agreements
June 2015
30 Jun - India: Comparables must be functional similar, not identical
30 Jun - India: “Groundbreaking” APA, taxpayer in IT industry
26 Jun - WCO: Guide on customs valuation, transfer pricing
22 Jun - Czech Republic: Next wave of transfer pricing inspections
22 Jun - India: No adjustment on share capital issuance
19 Jun - OECD: Comments, BEPS Action 8 (hard-to-value intangibles) discussion draft
13 Jun - India: APA rollback FAQs
12 Jun - Australia: Arm’s length, thin cap testing; transfer pricing landscape
12 Jun - OECD: Webcast provides BEPS status update
10 Jun - OECD: Initial impressions of BEPS country-by-country reporting implementation package
9 Jun - EU: Specific tax rulings requested from countries
8 Jun - Korea: Transfer pricing, customs valuations advance arrangements
8 Jun - OECD: Implementation package for BEPS country-by-country reporting
5 Jun - OECD: Initial impressions, BEPS Action 8 (hard-to-value intangibles)
5 Jun - Panama: Transfer pricing report deadline
5 Jun - India: Common director, management gives rise to “associated enterprises”
4 Jun - OECD: BEPS discussion draft, Action 8 (hard-to-value intangibles)
1 Jun - OECD: Comments on BEPS Action 8 (cost contribution arrangements)
1 Jun - Denmark: Enhanced transfter pricing reporting requirements, controlled transactions
May 2015
28 May - Sweden: Transfer pricing case pending high court decision
27 May - Poland: Proposals to revise transfer pricing documentation rules
26 May - India: Draft rules on “range concept,” multiple-year data
26 May - Turkey: APA update
18 May - Korea: Simplified APA program for foreign SMEs
13 May - Australia: Transfer pricing-related measures in federal budget 2015
12 May - Jamaica: Transfer pricing legislation tabled
11 May - Thailand: Draft transfer pricing legislation
6 May - Indonesia: APA guidelines
5 May - India: Most appropriate method, under cost contribution agreement
5 May - OECD: Discussion of BEPS Action 8 (cost contribution arrangements)
April 2015
30 Apr - Italy: Pending transfer pricing, international tax reform proposals
30 Apr - India: Factors for including, excluding comparables
29 Apr - OCED: Discussion draft, BEPS Action 8 (cost contribution arrangements)
29 Apr - Turkey: APA draft guidance
28 Apr - Korea: Related-party marketing fee subject to customs duty
27 Apr - OECD: BEPS Action 11 (improving analysis of BEPS)
15 Apr - Norway: Tax authorities may use "secret comparables"
6 Apr - India: Interest rate on related-party loans
6 Apr - France: Intergroup arrangements identified in tax-avoidance transactions
6 Apr - US: Related-party indebtedness section 965 repatriation rules
March 2015
31 Mar - Spain: Enhanced documentation, reporting proposed; following BEPS Action 13
31 Mar - India: APA rollback application deadline is extended
30 Mar - US: APMA program statistics for 2014
24 Mar - Denmark: Transfer pricing adjustment trends, forecast
23 Mar - EU: Risks of investigations into tax rulings
23 Mar - Taiwan: Amendments to transfer pricing rules
19 Mar - India: Promotion expenses subject to transfer pricing rules
19 Mar - EU: Automatic exchange of cross-border tax rulings
17 Mar - India: APA rollback rules, pre-filing consultations
17 Mar - US: Accounts receivable not creating related-party indebtedness
2 Mar - Australia: Guidance for invoking reconstruction provisions
2 Mar - Serbia: Arm’s length interest rates, related-party loans
2 Mar - Vietnam: Reporting related-party transactions, arm’s length compliance
February 2015
27 Feb - Australia: Initial steps for APA process
25 Feb - Canada: Intercompany management fees
23 Feb - Italy: Aligning customs valuation, transfer pricing policy
20 Feb - Iceland: Transfer pricing regulations
19 Feb - OECD: Consultation on transfer pricing, 19-20 March
17 Feb - Australia: Transfer pricing recordkeeping rules
17 Feb - Ukraine: Transfer pricing rules are revised, expanded
12 Feb - OECD: Transfer pricing documentation, country-by-country reporting
11 Feb - Taiwan: Separate analysis for certain controlled transactions
10 Feb - OECD: BEPS comments, transfer pricing guidelines
10 Feb - India: Transfer pricing documentation for certain electric companies
9 Feb - Switzerland: Transfer pricing implications of exchange rate movements
6 Feb - OECD: Update on BEPS country-by-country reporting
5 Feb - New Zealand: Effects of Australian rules on trans-Tasman operations
5 Feb - Indonesia: Mutual agreement procedures (MAP) guidance
3 Feb - Belgium: New wave of transfer pricing audits
3 Feb - South Africa: Withholding tax on transfer pricing adjustments
2 Feb - India: No government appeals in equity infusion cases
January 2015
29 Jan - Spain: Law modifying related-party transactions
27 Jan - Switzerland: "Big data" approach to transfer pricing
27 Jan - India: Resolving MAP IT-related cases with United States
21 Jan - India: Functional, asset and risk analysis
21 Jan - France: Transfer pricing measures are enacted
20 Jan - OECD: Comments concerning BEPS Action 10 (low value-adding services)
19 Jan - OECD: Comments concerning BEPS Action 14 (dispute resolution)
19 Jan - Australia: Arm's length consideration and related-party loans
16 Jan - EU: Investigation of Luxembourg transfer pricing rulings
13 Jan - Greece: APA procedures, process
12 Jan - Bolivia: Transfer pricing requirements
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