Tax News Flash | Transfer Pricing

TaxNewsFlash | Transfer Pricing

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

TaxNewsFlash-Transfer Pricing

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

March 2019

27 Mar - United States: APMA program, APA statistics for 2018

27 Mar - India: Arrangement for country-by-country report exchanges with United States is signed

22 Mar - OECD: Taxation of digital economy, public consultation update

22 Mar - United States: Foreign-initiated adjustments, competent authority guidance (IRS practice unit)

20 Mar - Canada: Transfer pricing measures in federal budget

20 Mar - India: No transfer pricing adjustment, profit margin greater than comparables

19 Mar - EU: Taxation of digital economy; considering possible outcomes

18 Mar - Poland: Application of transfer pricing regulations clarified for 2018 transactions

15 Mar - Australia: Guidance on inbound distribution arrangements, transfer pricing policies and arm’s length nature

15 Mar - India: Agreement with United States, exchange of country-by-country reports

14 Mar - India: Criteria for selecting transfer pricing comparable companies

14 Mar - Peru: Extended deadlines for filing country-by-country reports for 2017, 2018

13 Mar - Canada: MAP program summary, statistics for 2017

12 Mar - Peru: Tax authorities communication regarding local filing of country-by-country reports for FY 2017

11 Mar - UK: Proposed digital services tax; overview and possible implications for U.S. businesses

11 Mar - United States: IRS transfer pricing teams must consult competent authority

8 Mar - United States: Competent authority process, under tax treaty’s MAP article

8 Mar - Hong Kong: Transfer pricing compliance for 2018-19 year of assessment

8 Mar - OECD: KPMG comments concerning consultation on tax challenges of digitalisation

8 Mar - UK: Insight into HMRC’s profit diversion compliance facility

7 Mar - Luxembourg: EC state aid investigation, tax rulings granted Finnish-headquartered company

6 Mar - France: Draft proposal for digital services tax

4 Mar - Serbia: Related-party interest rates for 2019, transfer pricing documentation implications

4 Mar - United States: “Functional cost diagnostic model” for review of APA requests

1 Mar - UK: HMRC profit-diversion compliance facility; verifying transfer pricing and BEPS compliance

September 2018

28 Sep - KPMG report: Post-BEPS issues concerning cost sharing arrangements in transfer pricing 

27 Sep - Andorra: Country-by-country reporting and notification rules

26 Sep - Korea: Transfer pricing-related proposals in 2019 tax revision legislation

25 Sep - Panama: New version of form for transfer pricing report

21 Sep - UK: Implications of Ireland’s proposed changes to transfer pricing regime for UK groups with Irish financing structures

19 Sep - Luxembourg: Non-taxation of U.S. multinational corporation not illegal state aid (EC investigation)

18 Sep - Nigeria: Public notice published, country-by-country reporting regulations

18 Sep - OECD: Saudi Arabia signs BEPS multilateral convention

18 Sep - United States: IRS reminders relating to Form 8975 “Country-by-Country Report”

17 Sep - Poland: Interactive forms available, simplified transfer pricing reports

13 Sep - Ireland: Proposed controlled foreign company (CFC) regime; profit determined using arm’s length, transfer pricing principles

13 Sep - OECD: Updated country-by-country reporting guidance; dividends received, employee numbers

12 Sep - Asia Pacific: Transfer pricing review (2018)

12 Sep - Malta: Reminder to file country-by-country reporting notification

10 Sep - China: WCO guide customs valuation and transfer pricing (2018 edition); implications for Chinese entities

10 Sep - KPMG report: OECD discussion draft, transfer pricing aspects of financial transactions

7 Sep - OECD: New transfer pricing country profiles (Costa Rica, Greece, South Korea, Panama, Seychelles, South Africa, Turkey)

July 2018

25 Jul - Canada: Statistics from 2017 advance pricing arrangement (APA) program; record number of APA cases

25 Jul - United States: IRS updates country-by-country reporting guidance, information

24 Jul - United States: Ninth Circuit reverses Tax Court, upholds cost-sharing regulations

24 Jul - Australia: Proposal to expand “significant global entity” definition, aligning country-by-country reporting with OECD model requirements

24 Jul - Belgium: Civil penalties for transfer pricing documentation compliance failures

20 Jul - Poland: Proposed changes to transfer pricing rules

18 Jul - Netherlands: Implications of Dutch transfer pricing decree on OECD discussion draft on transfer pricing of financial transactions

17 Jul - United States: Transfer pricing in the age of tax reform

16 Jul - India: “Substantive revision” of bilateral APA with UK

13 Jul - Nigeria: Country-by-country reporting guidelines

12 Jul - Czech Republic: What to expect in a transfer pricing inspection

12 Jul - France: Transfer pricing documentation requirements, clarified and detailed

11 Jul - KPMG report: Initial impressions of OECD discussion draft on transfer pricing for financial transactions

10 Jul - Curaçao: Legislation implementing BEPS recommendations includes transfer pricing reporting obligations

6 Jul - New Zealand: New BEPS law enacted, includes transfer pricing measures

5 Jul - Hong Kong: Passage of transfer pricing legislation (BEPS bill); most provisions effective from assessment year 2018/2019

5 Jul - India: Guidance on confidentiality, appropriate use of country-by-country reports

3 Jul - Nigeria: Transfer pricing update, including country-by-country reporting

3 Jul - OECD: BEPS discussion draft, transfer pricing aspects of financial transactions

March 2018

30 Mar - United States: APMA program, APA statistics for 2017

30 Mar - United States: IRS guidance on country-by-country reporting by “specified national security contractors”

26 Mar - Argentina: Country-by-country notification deadline extended to 2 May 2018

26 Mar - India: APA authorities accept customs valuation as arm’s length price for transfer pricing purposes

23 Mar - UK: Voluntary preparation of Master file, Local file documentation; UK-parented multinational entities

22 Mar - OECD: Additional guidance on attribution of profits to permanent establishments (BEPS Action 7)

21 Mar - EU: Proposals for taxation of digital businesses

21 Mar - Spain: Retroactive transfer pricing adjustments, considerations for customs valuation purposes

20 Mar - Nigeria: Country-by-country reporting to be added to transfer pricing rules

19 Mar - Dominican Republic: Tax authorities requesting transfer pricing studies, verifying interest deductibility of related-party transactions

16 Mar - OECD: Interim report, tax challenges from digitalisation (BEPS)

16 Mar - Singapore: Discussion of revised transfer pricing guidelines

16 Mar - Poland: Extended deadline for transfer pricing documentation requirements

16 Mar - India: Lower house passes Finance Bill 2018; changes to country-by-country reporting, Master file rules

16 Mar - Serbia: Arm’s length interest rates “rulebook” for 2018; transfer pricing documentation implications

13 Mar - EU: Disclosure rules, reportable cross-border arrangements by tax advisers

12 Mar - OECD: Improving tax dispute resolution mechanisms under BEPS Action 14, including MAP access

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

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