Recent Articles
May 2023
22 May - New Zealand: May 2023 Tax Bill includes Pillar Two global minimum tax rules
19 May - Australia: Updated draft practical compliance guideline on intangibles arrangements
19 May - EU: Action seeking annulment of EU minimum tax directive (EU General Court)
17 May - Switzerland: Transfer pricing topics of focus in audits and ruling requests
16 May - Indonesia: Overview of transfer pricing environment
12 May - UAE: New transfer pricing documentation requirements
11 May - Brazil: OECD-aligned transfer pricing rules passed by Senate
10 May - United States: KPMG analysis of IRS 2022 APA statistics
8 May - Kenya: Transfer pricing, direct, and indirect tax measures in Finance Bill, 2023
8 May - KPMG report: Progress on improving mutual agreement procedure
1 May - United States: IRS guidance on review and acceptance of APA submissions
April 2023
28 Apr - Japan: 2023 tax reform includes income inclusion rule, CFC regime
24 Apr - Korea: Criteria for selection of comparable companies (Tax Tribunal decision)
20 Apr - Lithuania: Draft legislation implementing public country-by-country reporting
17 Apr - Saudi Arabia: Amendments to transfer pricing bylaws
12 Apr - KPMG report: Transfer pricing and ESG—public tax strategies and tax transparency
11 Apr - Australia: Draft legislation for public country-by-country (CbC) reporting
5 Apr - Ireland: Draft legislation on implementation of Pillar Two global minimum tax
4 Apr - Poland: Guidance on resale price method
3 Apr - UK: Implementation of Pillar Two global minimum tax under Spring Finance Bill 2023
March 2023
31 Mar - Brazil: OECD-aligned transfer pricing rules passed by Chamber of Deputies, await vote in Senate
30 Mar - Serbia: Rulebook on arm’s length interest rates for 2023
29 Mar - United States: APMA program, APA statistics for 2022 (IRS Announcement 2023-10)
29 Mar - Vietnam: MAAC signed, intention to implement Pillar Two global minimum tax
27 Mar - KPMG report: Evaluating the equivalence of cost-sharing and cost contribution arrangements
27 Mar - Sweden: Draft legislation implementing public country-by-country reporting presented to parliament
23 Mar - Germany: Public consultation on implementation of Pillar Two global minimum tax
23 Mar - Sweden: Proposed additions to interim report on implementation of EU global minimum tax directive
22 Mar - Spain: Public consultation on Pillar Two global minimum tax
21 Mar - Montenegro: Amendments to tax law include changes to Local file requirements
20 Mar - Korea: Advance customs valuation arrangement, coordination with transfer pricing
16 Mar - OECD: Public consultation meeting on implementation under Pillar Two
15 Mar - Poland: Extended deadline for submitting ORD-U reports
14 Mar - Thailand: Measures to support implementation of Pillar Two global minimum tax rules
10 Mar - Cyprus: Frequently asked questions on transfer pricing documentation rules
10 Mar - Luxembourg: Draft legislation for implementation of public country-by-country reporting
8 Mar - KPMG report: Transfer pricing implications of intercompany fees for internal carbon pricing
7 Mar - Poland: Public consultation on transfer pricing cost-plus method regulations
February 2023
27 Feb - Brazil: Guidance on new OECD-aligned transfer pricing rules
24 Feb - South Africa: Proposed legislative framework for APAs in 2023 budget
16 Feb - OECD: Comments on public consultation documents on implementation under Pillar Two
15 Feb - UK: HMRC transfer pricing and diverted profits tax statistics for year ended 31 March 2022
13 Feb - Sweden: Proposal for implementation of public country-by-country reporting
6 Feb - Qatar: Amendment of transfer pricing-related provisions of Income Tax Law for 2018
3 Feb - KPMG report: Comments on public consultation documents on implementation under Pillar Two
2 Feb - KPMG report: U.S. accounting questions related to new GloBE rules
2 Feb - OECD: Administrative guidance for implementation of Pillar Two global minimum tax rules
January 2023
31 Jan - Estonia: Country-by-country reporting and transfer pricing documentation deadlines
30 Jan - OECD: Comments on public consultation document on Amount B under Pillar One
25 Jan - KPMG report: Comments on public consultation document on Amount B under Pillar One
24 Jan - OECD: Comments on public consultation document on withdrawal of DSTs under Pillar One
23 Jan - Hungary: Changes to transfer pricing rules, including reporting and documentation
20 Jan - KPMG report: Comments on public consultation document on withdrawal of DSTs under Pillar One
20 Jan - KPMG report: Where next for Amount B?
19 Jan - South Africa: Interpretation note providing transfer pricing guidance on intragroup loans
18 Jan - OECD: Revenue gains from BEPS 2.0 predicted to be higher than previously expected
13 Jan - OECD: Manal Corwin appointed new Director of its Centre for Tax Policy and Administration
13 Jan - Slovakia: Changes to content of transfer pricing documentation
12 Jan - Panama: Deadline for submitting 2021 country-by-country reports extended to 15 January 2023
11 Jan - Spain: Public country-by-country reporting implemented
10 Jan - North Macedonia: Proposed changes to transfer pricing reporting
3 Jan - Montenegro: Arm’s length interest rate for 2023
3 Jan - Poland: Interest rates for transfer pricing purposes
2022 Articles
December 2022
29 Dec - Brazil: Draft legislation to align transfer pricing rules with OECD Transfer Pricing Guidelines
22 Dec - Morocco: Temporary suspension of country-by-country report local filing requirement
22 Dec - Belgium: Year-end transfer pricing considerations
22 Dec - Latvia: Penalty for non-compliant transfer pricing documentation
21 Dec - KPMG report: Pillar Two implementation package, initial observations and analysis
20 Dec - UAE: New transfer pricing rules
19 Dec - Serbia: Rulebook on arm’s length interest rates for 2022
19 Dec - KPMG report: Europe, Middle East, and Africa (EMA) transfer pricing insights
16 Dec - Switzerland: Parliament approves constitutional amendment to implement Pillar Two global minimum tax
16 Dec - Korea: Tax authority’s determination of arm’s length price upheld (Tax Tribunal decision)
16 Dec - EU: Council adopts EU minimum tax directive
15 Dec - Hungary: Guidance on transfer pricing reporting
13 Dec - EU: Member states in the EU reach agreement to implement Pillar Two (updated)
13 Dec - United States: Consideration of tax consequences in determining arm’s length result (GLAM)
13 Dec - Czech Republic: Tax loss from transfer pricing adjustments abroad denied (court decision)
13 Dec - Poland: Amendments to decrees on transfer pricing reporting
12 Dec - UAE: Implementation of new federal corporate income tax system, related transfer pricing rules
12 Dec - KPMG report: U.S. administrative law basics for transfer pricing professionals
9 Dec - KPMG report: Public consultation on Amount B under Pillar One, initial observations and analysis
9 Dec - Slovakia: Changes to transfer pricing rules and limitations on deductibility of interest
9 Dec - Slovakia: Public country-by-country reporting implemented
8 Dec - OECD: Public consultation document on Amount B under Pillar One
7 Dec - United States: MAP and the exhaustion of remedies for FTC purposes
6 Dec - KPMG report: OECD official provides update on work on Amount B
6 Dec - EU: Minimum tax directive proposal removed from ECOFIN meeting agenda
6 Dec - Kenya: Country-by-country reporting multilateral competent authority agreement signed
6 Dec - Romania: Public country-by-country reporting implemented
November 2022
30 Nov - Poland: Legislation implementing “public” country-by-country reporting directive announced
30 Nov - KPMG report: Transfer pricing in the soccer field
29 Nov - KPMG report: Key takeaways from the OECD’s 2021 mutual agreement procedure (MAP) statistics
28 Nov - China: Advance pricing arrangement annual report for 2021
28 Nov - Qatar: Transfer pricing documentation requirements
22 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2021
22 Nov - EU: Public country-by-country reporting implementation summary
22 Nov - Malta: Formal transfer pricing rules published
17 Nov - OECD: Aggregated country-by-country reporting data
16 Nov - United States: Year-end tax discussion ideas for international tax and transfer pricing
14 Nov - Montenegro: Guidance under new transfer pricing rules
11 Nov - UK: Implications of interest rate increases for transfer pricing
3 Nov - Hungary: Draft legislation to implement public country-by-country reporting
October 2022
27 Oct - Australia: Public country-by-country (CbC) reporting proposed in 2022-2023 federal budget
25 Oct - Netherlands: Consultation on implementation of Pillar Two rules
25 Oct - Poland: Updated transfer pricing reporting obligations guidebook
24 Oct - Poland: Transfer pricing measures in legislation amending “Polish Deal”
20 Oct - Romania: Bill implementing public country-by-country (CbC) reporting directive
20 Oct - South Africa: Guidance on definition of “associated enterprises” under transfer pricing rules
19 Oct - KPMG report: Initial observations of OECD report on tax incentives and the global minimum tax
14 Oct - OECD: Updated guidance on implementation of country-by-country reporting
14 Oct - KPMG report: Current state and trends in transfer pricing for intercompany financial transactions
13 Oct - KPMG report: Global formulary apportionment
13 Oct - KPMG report: The arm’s length standard after the pillars
13 Oct - Australia: Consultation paper on BEPS 2.0
12 Oct - KPMG report: Transfer pricing considerations in the age of precision medicine
6 Oct - OECD: Report on tax incentives and the global minimum tax
4 Oct - Philippines: Guidelines and procedures for requesting MAP
3 Oct - KPMG report: In defense of the arm’s length principle
September 2022
30 Sep - OECD: Inclusive Framework on BEPS meeting scheduled for 6 - 7 October 2022
30 Sep - Slovakia: Proposed changes to transfer pricing rules and limitations on deductibility of interest
29 Sep - South Africa: Increased transfer pricing scrutiny
28 Sep - Belgium: Deadline for filing Local file forms is 17 October 2022
28 Sep - Germany: Draft legislation on submission of transfer pricing documentation in tax audit
20 Sep - United States: SEC signals support for country-by-country reporting
8 Sep - Cyprus: Guidance regarding transfer pricing documentation
6 Sep - OECD: Pascal Saint-Amans to retire 31 October 2022
1 Sep - Denmark: Reminder of 6 September deadline for transfer pricing documentation
August 2022
30 Aug - Mexico: Transfer pricing documentation for derivative financial transactions
29 Aug - Poland: Transfer pricing measures in draft bill
25 Aug - OECD: Comments on progress report on Amount A of Pillar One
19 Aug - KPMG report: Comments on progress report on Amount A of Pillar One
19 Aug - KPMG report: European Commission business tax agenda
18 Aug - United States: Tax Court’s determination of transfer pricing method, on remand from Eighth Circuit
12 Aug - Australia: Proposal for increased public reporting of tax and country-by-country information
12 Aug - Malaysia: Effective tax rate; country-by-country reporting data used for transfer pricing purposes
10 Aug - Italy: Tax audits based on cross-border transactions, transfer pricing issues
10 Aug - Korea: Tax reform proposals include transfer pricing documentation and Pillar Two measures
9 Aug - Philippines: Guidance for taxpayers seeking MAP assistance
5 Aug - Australia: Consultation paper, multinational tax integrity and tax transparency
July 2022
29 Jul - Lithuania: Changes to APA rules
26 Jul - KPMG report: Amount B—the forgotten piece of the Pillar One jigsaw
22 Jul - Ireland: BEPS 2.0 implications for aviation sector
20 Jul - UK: Draft legislation to implement Pillar Two published
18 Jul - KPMG report: The diverging paths of Pillars One and Two
18 Jul - Czech Republic: Tax priorities of the Czech EU Presidency
14 Jul - EU: Update on minimum tax directive; priority of new presidency of the European Council
12 Jul - Netherlands: New decree on profit attribution to permanent establishments
11 Jul - OECD: Progress report on Amount A of Pillar One, including revised schedule; public consultation
11 Jul - Cyprus: Transfer pricing documentation legislation
11 Jul - Saudi Arabia: Proposed amendments to transfer pricing bylaws; comments due 30 July 2022
7 Jul - Netherlands: Details about changes in new transfer pricing decree
5 Jul - Poland: Transfer pricing measures in proposed legislation
1 Jul - Netherlands: New transfer pricing decree
1 Jul - KPMG report: Environmental, social, and governance (ESG) and transfer pricing
June 2022
29 Jun - Australia: Proposed amendments to thin capitalisation rules, effect on arm's length debt test
28 Jun - Malta: Update on transfer pricing landscape
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
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
May 2022
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
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
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
April 2022
28 Apr - KPMG report: Transfer pricing and the audit committee agenda, implementation steps
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)
March 2022
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
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
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)
February 2022
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
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
January 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
2021 Articles
December 2021
22 Dec - EU: Directive to implement Pillar Two is proposed
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 - KPMG report: Uneven transfer pricing implications of COVID-19 pandemic
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 - Zambia: Transfer pricing measures included in 2022 budget
1 Dec - EU: “Public” country-by-country reporting directive published in EU Official Journal
November 2021
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
October 2021
22 Oct - Ireland: Transfer pricing measures included in Finance Bill 2021
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
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)
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
September 2021
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
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
August 2021
31 Aug - Germany: New administrative guidelines for transfer pricing
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)
July 2021
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
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 - KPMG report: OECD/G20 Inclusive Framework agreement on BEPS 2.0
June 2021
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)
May 2021
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
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