May 2024

30 May - OECD: Statement by co-chairs of Inclusive Framework on BEPS indicates final negotiations on Pillar One Amount A (including text of multilateral convention) and Amount B nearing completion

30 May - Australia: House passes legislation clarifying meaning of “exploration for petroleum,” updating transfer pricing guidance

30 May - Japan: Explanation of guidance on income inclusion rule, associated forms and schedules

29 May - Belgium: Due date for first GloBE registration is July 13, 2024

28 May - Cyprus: Final version of 2022 transfer pricing documentation form

24 May - Crown Dependencies: Details on plans to implement Pillar Two global minimum tax

23 May - Australia: KPMG comments on subordinate draft legislation implementing Pillar Two global minimum tax rules

23 May - Spain: Consultation on draft legislation implementing Pillar Two global minimum tax

23 May - UK: HMRC guidance on registration under Pillar Two global minimum tax regime

22 May - Belgium: GloBE registration requirements for multinational and large domestic groups

22 May - Switzerland: Cantonal tax law changes in response to Pillar Two global minimum tax

21 May - Denmark: Proposed amendments to Pillar Two legislation submitted to Parliament

21 May - Poland: Consultation on Pillar Two global minimum tax rules extended

16 May - Kenya: Tax proposals in Finance Bill, 2024 include implementation of Pillar Two global minimum tax

15 May - Czech Republic: Transfer prices for advertising expenses (Supreme Administrative Court decision)

15 May - Malaysia: Updated advance pricing arrangement guidelines

3 May - Belgium: Amendments to Pillar Two global minimum tax rules

2 May - KPMG report: Employee data reporting for public country-by-country reporting

2 May - Norway: Pillar Two global minimum tax implemented in Supplementary Tax Act

April 2024

30 Apr - Slovakia: Guidelines on transfer pricing documentation for 2023

30 Apr - OECD: Consolidated commentary on Pillar Two rules, updated Pillar Two examples

29 Apr - OECD: Tax inspectors without borders 2024 annual report, new focus on country-by-country data and digital economy

29 Apr - Poland: Draft bill implementing Pillar Two global minimum tax published

26 Apr - Estonia: Legislation implementing Pillar Two global minimum tax rules approved by Parliament

26 Apr - EU: European Parliament adopts resolution on transfer pricing directive

26 Apr - Greece: Legislation implementing Pillar Two global minimum tax rules enacted

26 Apr - Iceland: Intention announced to implement Pillar Two global minimum tax rules

25 Apr - Germany: Draft bill for Annual Tax Act 2024 includes Pillar Two changes, other tax developments

25 Apr - Korea: Interest deductions could be challenged on arm’s length grounds, but not wholly denied as tax avoidance (Tax Tribunal decision)

24 Apr - UK: Related-party interest arm’s length but still disallowed based on unallowable purpose (Court of Appeal decision)

23 Apr - Poland: Public country-by-country reporting implemented

22 Apr - Austria: Draft law implementing public country-by-country reporting

19 Apr - Germany: New transfer pricing regulations for intra-group financial transactions

19 Apr - Australia: KPMG comments on draft legislation implementing Pillar Two global minimum tax rules

18 Apr - Australia: Performance audit report on management of transfer pricing for related-party debt

11 Apr - Korea: Guidance regarding amendments to Pillar Two rules

10 Apr - Cyprus: FAQs on adoption of new transfer pricing legislation

8 Apr - Bahrain: Deadline for country-by-country reporting filings for FY 2023 is 31 December 2024

8 Apr - Belgium: Draft amendments to Pillar Two minimum tax rules

8 Apr - KPMG report: Transfer pricing and ESG—improving governance by operationalizing transfer pricing

8 Apr - Liechtenstein: Guidance on Pillar Two minimum tax rules

8 Apr - Poland: Public country-by-country reporting bill approved by lower house of Parliament, updated national list of non-cooperative jurisdictions

8 Apr - Sweden: Draft amendments to Pillar Two minimum tax rules

8 Apr - UAE: Consultation on Pillar Two minimum tax rules

5 Apr - Hungary: Audit plan for 2024 focuses on transfer pricing

4 Apr - Australia: New 2024 reportable tax position schedule released, with new questions on intangibles migration arrangements

2 Apr - KPMG report: Recent DCL and Pillar Two guidance, comments and recommendations

March 2024

29 Mar - Netherlands: Public country-by-country reporting implemented

29 Mar - United States: APMA program, APA statistics for 2023

29 Mar - KPMG report: New UK transfer pricing guidance on allocation of risk in controlled transactions

28 Mar - Luxembourg: Guidance under Pillar Two law relating to inclusion of deferred tax assets and liabilities in computing effective tax rate

28 Mar - South Africa: Comparable uncontrolled price method held most reliable method (court decision)

25 Mar - Ireland: Tax changes for the asset management and funds industry, including Pillar Two rules

22 Mar - Australia: Consultation on draft legislation implementing Pillar Two global minimum tax rules

21 Mar - Finland: Legislation implementing Pillar Two global minimum tax

19 Mar - KPMG report: Amount B compliance challenges

19 Mar - KPMG report: Implications of ICAP statistics

15 Mar - Estonia: Draft bill implementing public country by country reporting submitted to Parliament

15 Mar - EU: European Parliament committee adopts report on transfer pricing directive

15 Mar - EU: Taxpayer appeals General’s Court dismissal of challenge to EU minimum tax directive

15 Mar - UK: Finance Act 2024 includes amendments to Pillar Two minimum tax rules

14 Mar - Cyprus: Draft legislation implementing Pillar Two global minimum tax rules

14 Mar - Jamaica: Tax measures in 2024-2025 budget include Pillar Two global minimum tax rules

14 Mar - Malta: Guidance on implementation of Pillar Two global minimum tax

12 Mar - United States: Updated digital services tax agreement with Turkey

12 Mar - Australia: Taxpayer failed to meet burden of proof in transfer pricing dispute (Full Federal Court decision)

11 Mar - Italy: Transfer pricing requirements for investment manager exemption

6 Mar - Australia: KPMG comments on revised draft legislation implementing public country-by-country reporting

5 Mar - Poland: Bill implementing Pillar Two global minimum tax

4 Mar - Cambodia: Market interest rate for related party loans; incentives for voluntary amendment of tax declarations

February 2024

29 Feb - Cyprus: Deadline to submit 2022 return for taxpayers required to submit transfer pricing documentation extended

29 Feb - OECD: Report to G20 Finance Ministers and Central Bank Governors, updates on developments in international tax reforms

28 Feb - Greece: Proposed legislation implementing Pillar Two global minimum tax

28 Feb - Malta: Legislation implementing Pillar Two global minimum tax

28 Feb - South Africa: Draft legislation implementing Pillar Two global minimum tax

23 Feb - Slovakia: Legislation implementing Pillar Two global minimum tax passed by Parliament

22 Feb - New Zealand: No adoption of Amount B

21 Feb - KPMG report: Overview and initial observations on Pillar One – Amount B

21 Feb - KPMG report: HMRC guidance on OECD’s control of risk framework

21 Feb - Ethiopia: New transfer pricing rules

21 Feb - Kenya: Transfer pricing developments

20 Feb - Nigeria: Migration of electronic platform for filing transfer pricing returns and country-by-country notifications

20 Feb - Singapore: Tax measures in budget 2024 include Pillar Two global minimum tax rules

19 Feb - OECD: Report on Amount B under Pillar One

15 Feb - United States: Treasury statement regarding extended agreement on digital services taxes imposed by Austria, France, Italy, Spain, United Kingdom

12 Feb - EU: VAT treatment of transfer pricing adjustments (CJEU referral from Romania)

12 Feb - Australia: Revised draft legislation implementing public country-by-country reporting

9 Feb - Belgium: Public country-by-country reporting implemented

9 Feb - EU: Formal notices to nine member states on failure to transpose minimum tax directive

9 Feb - Spain: Draft legislation implementing Pillar Two global minimum tax

8 Feb - KPMG report: Pillar Two implications of U.S. self-initiated transfer pricing true-ups

8 Feb - KPMG report: Legal advice memorandum shows IRS approach to intercompany debt pricing

6 Feb - Malta: Transfer pricing guidelines

5 Feb - Japan: Additional guidance on income inclusion rule

2 Feb - Australia: Proposed retroactive adoption of updated OECD transfer pricing guidance

2 Feb - Cyprus: Proposed increase to Local file thresholds

2 Feb - Indonesia: New regulations for transfer pricing documentation, MAPs, APAs

2 Feb - Malta: Time limitation on applicability of grandfathering provision under transfer pricing rules

1 Feb - KPMG report: Europe, Middle East, and Africa (EMA) transfer pricing insights (February 2024)

January 2024

30 Jan - EU: Public country-by-country reporting implementation summary

30 Jan - Latvia: Draft legislation implementing Pillar Two global minimum tax

30 Jan - Poland: Procedure for filing transfer pricing reporting forms for acquired entities

30 Jan - UK: Updated transfer pricing guidance on allocation of risk in controlled transactions

29 Jan - OECD: Aggregated ICAP statistics

29 Jan - UK: Government response to consultations on proposed changes to transfer pricing and international tax rules

25 Jan - Colombia: New deadlines for transfer pricing documentation

22 Jan - Australia: Practical compliance guideline on intangibles arrangements

22 Jan - United States: Resurgence of transfer pricing penalties

19 Jan - Bulgaria: Public country-by-country reporting implemented

19 Jan - Czech Republic: Public country-by-country reporting implemented

19 Jan - EU: Challenge to EU global minimum tax directive dismissed (EU General Court judgment)

18 Jan - Italy: Pillar Two global minimum tax rules implemented

17 Jan - Czech Republic: Legislation introducing top-up tax, implementing EU directive on global minimum tax, now effective

17 Jan - EU: Pillar Two global minimum tax implementation summary

17 Jan - Italy: New tax calendar, implications for transfer pricing documentation

16 Jan - Belgium: Lower house of Parliament adopts draft law implementing public country-by-country reporting

16 Jan - Romania: Law implementing Pillar Two global minimum tax

16 Jan - UK: Updates on Pillar Two, including draft HMRC guidance on proposed rules

11 Jan - France: Tax-related provisions in finance law for 2024, including Pillar Two rules and transfer pricing documentation changes

11 Jan - KPMG report: Comments on European Commission consultation on transfer pricing initiative

10 Jan - Korea: Amendments to Pillar Two rules enacted

8 Jan - Poland: Guidance on obligation to submit transfer pricing information, base interest rates and margin rates

4 Jan - Qatar: Extended deadline for country-by-country reports and notifications

2 Jan - United States: Effect of group membership on arm’s length interest rate on intragroup loans (Chief Counsel legal advice memorandum)

2 Jan - Hong Kong: Consultation paper on implementation of Pillar Two global minimum tax

2 Jan - KPMG report: Pillar Two rules and the asset management industry

2023 Articles

December 2023

29 Dec - Zimbabwe: Legislation implementing Pillar Two global minimum tax enacted

26 Dec - China: Advance pricing arrangement annual report for 2022

22 Dec - EU: EC publishes FAQs on interpretation and transposition of EU global minimum tax

22 Dec - Switzerland: Law implementing Pillar Two minimum tax rule enacted

20 Dec - KPMG report: New administrative guidance on Pillar Two rules, initial observations and analysis

20 Dec - EU: Pillar Two global minimum tax implementation summary

20 Dec - Luxembourg: Law implementing Pillar Two global minimum tax enacted

20 Dec - Netherlands: 2024 Tax Plan package and law implementing Pillar Two global minimum tax enacted

20 Dec - Netherlands: Senate approves legislation implementing public country-by-country reporting

19 Dec - Ireland: Legislation implementing Pillar Two signed into law

19 Dec - Hong Kong: Update on implementation of Pillar Two global minimum tax

18 Dec - Saudi Arabia: Zakat treatment of related-party transactions; thresholds for transfer pricing documentation for Zakat payers

18 Dec - OECD: Further administrative guidance on Pillar Two rules; statement on timeline of Pillar One multilateral convention

15 Dec - Belgium: Pillar Two global minimum tax rules adopted by Parliament

15 Dec - KPMG report: Transfer pricing implications of Pillar Two minimum tax rules

14 Dec - Luxembourg: European Commission erred in finding grant of State aid based on OECD Transfer Pricing Guidelines (CJEU judgment)

14 Dec - Moldova: Public country-by-country reporting implemented

8 Dec - Australia: Judgment on embedded royalties and application of diverted profits tax (DPT) publicly released (Federal Court decision)

8 Dec - Croatia: Consultation on draft legislation implementing Pillar Two global minimum tax

8 Dec - Hungary: Legislation implementing Pillar Two global minimum tax enacted

8 Dec - Moldova: Draft law implementing country-by-country reporting

8 Dec - UK: Finance Bill 2024, including amendments to Pillar Two minimum tax rules 

6 Dec - Luxembourg: Amended draft law implementing Pillar Two global minimum tax

5 Dec - KPMG report: OECD official provides update on expected transfer pricing guidance

1 Dec - KPMG report: IRS large foreign-owned transfer pricing initiative aimed at inbound distributors

1 Dec - Australia: Taxpayer liable for withholding tax on embedded royalties, application of DPT (Federal Court decision)

November 2023

29 Nov - Vietnam: Resolution adopting Pillar Two global minimum tax

28 Nov - Poland: Extended deadline for submitting certain transfer pricing reporting forms

27 Nov - Greece: Public country-by-country reporting implemented

27 Nov - UK: Update on consultation on proposed changes to transfer pricing and permanent establishment rules

27 Nov - KPMG report: Transfer pricing of financial transactions

24 Nov - KPMG report: Transfer pricing takeaways from 2022 MAP statistics

24 Nov - Austria: Updated draft legislation implementing Pillar Two global minimum tax

24 Nov - Norway: Amended draft legislation implementing Pillar Two global minimum tax

24 Nov - Slovenia: Updated draft legislation implementing Pillar Two global minimum tax

21 Nov - OECD: Aggregated country-by-country reporting data

21 Nov - KPMG report: Pillar Two implications for “U.S. sandwich structures”

17 Nov - Czech Republic: Proposed direct and indirect tax changes, including public country-by-country reporting

16 Nov - Bermuda: Third public consultation related to proposed corporate income tax

16 Nov - Poland: Extended deadlines for transfer pricing reporting

14 Nov - Germany: Law implementing Pillar Two global minimum tax passed by lower house of Parliament

14 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2022

13 Nov - Barbados: Proposed rules to implement Pillar Two global minimum tax

13 Nov - Brazil: Modification of multiple-year data table under new transfer pricing rules

10 Nov - Liechtenstein: Law implementing Pillar Two global minimum tax adopted by Parliament

9 Nov - EU: Member states approve statements of EU Council and European Commission reconfirming support for Pillar One and Pillar Two

9 Nov - Ireland: Judgment of General Court regarding tax rulings issued to multinational group must be set aside (CJEU Advocate General opinion)

9 Nov - Cyprus: Consent to Pillar Two global minimum tax rules

9 Nov - Estonia: Legislative proposal implementing Pillar Two global minimum tax rules

9 Nov - Finland: Reservations on proposed EU BEFIT, transfer pricing, and head office tax system directives

9 Nov - Greece: Public consultation on implementation of public country-by-country reporting

9 Nov - Sweden: Reservations on proposed EU transfer pricing directive

8 Nov - United States: Brazilian legal restriction not taken into account in determining arm’s length transfer price under section 482 (U.S. Tax Court)

8 Nov - Australia: Updated practice compliance guideline on simplified transfer pricing record-keeping options, new safe harbor

8 Nov - Malaysia: Finance Bill (No. 2) 2023 includes proposed Pillar Two rules

6 Nov - OECD: Public consultation on additional toolkit to support developing countries in addressing BEPS risks when pricing minerals

6 Nov - Sweden: Updated draft legislation implementing Pillar Two global minimum tax

October 2023

31 Oct - Malta: Tax measures in budget 2024, including deferral of implementation of Pillar Two global minimum tax

31 Oct - Poland: Deadline for transfer pricing reporting for 2022 extended

31 Oct - UAE: Transfer pricing guide issued

27 Oct - Lithuania: Draft legislation implementing Pillar Two global minimum tax

27 Oct - KPMG report: U.S. transfer pricing and international tax year-end considerations

25 Oct - Australia: Extended due date for filing country-by-country (CbC) reports, Master and Local files

23 Oct - Hungary: Proposed legislation implementing Pillar Two global minimum tax

23 Oct - Korea: Services fee arrangement satisfied arm’s length principle (Tax Tribunal decision)

23 Oct - Korea: “Transfer pricing adjustment” under supply contract not “subsequent proceeds” for customs purposes (Supreme Court decision)

23 Oct - Romania: Proposed legislation implementing Pillar Two global minimum tax

23 Oct - Switzerland: Transfer pricing adjustment invalid because inconsistent with OECD guidelines (Federal Administrative Court decision)

20 Oct - Ireland: Tax proposals in Finance bill 2023 include implementation of Pillar Two global minimum tax

19 Oct - France: Tax measures in 2024 draft finance law include Pillar Two implementation and transfer pricing documentation changes

17 Oct - KPMG report: Multilateral conventions on Amount A of Pillar One and Pillar Two subject to tax rule, initial observations and analysis

17 Oct - KPMG report: Mexico’s reference effective tax rates aid voluntary compliance

17 Oct - Poland: New electronic templates for transfer pricing reporting

17 Oct - Belgium: Public country-by-country reporting draft law approved

16 Oct - UK: Further analysis of Pillar Two global minimum tax rules in updated Finance Bill 2023 draft legislation

12 Oct - Cyprus: Status of bilateral Competent Authority Arrangement for exchange of CbC reports with United States

11 Oct - OECD: Multilateral convention to implement Amount A of Pillar One; implementation handbook for Pillar Two global minimum tax

11 Oct - United States: Treasury request for public input on OECD multilateral convention to implement Amount A of Pillar One

11 Oct - Poland: Guidance on transfer pricing cost-plus method

6 Oct - Bermuda: Second public consultation related to proposed corporate income tax

6 Oct - Cyprus: Public consultation on draft legislation implementing Pillar Two global minimum tax

5 Oct - Bulgaria: Public consultation on draft legislation implementing Pillar Two global minimum tax

5 Oct - France: Draft legislation implementing Pillar Two global minimum  tax

5 Oct - Latvia: Public country-by-country reporting legislation approved

5 Oct - Austria: Draft legislation implementing Pillar Two global minimum tax

4 Oct - Brazil: New transfer pricing rules published

4 Oct - Denmark: Updated draft legislation implementing Pillar Two global minimum tax

3 Oct - OECD: Multilateral convention to facilitate implementation of Pillar Two subject to tax rule

3 Oct - Japan: Guidance on income inclusion rule

September 2023

29 Sep - Slovakia: Draft legislation implementing Pillar Two global minimum tax

29 Sep - UK: Updated Finance Bill 2023 draft legislation, including Pillar Two global minimum tax rules

26 Sep - Poland: Amendments to decrees on transfer pricing reporting now effective

25 Sep - Korea: Fee paid to foreign parent company was royalty subject to withholding tax (Tax Tribunal decision)

20 Sep - OECD: Comments on public consultation document on Amount B under Pillar One

20 Sep - Kenya: Public consultation on draft transfer pricing rules

19 Sep - Denmark: Transfer pricing adjustments on intercompany transactions between oil and gas company and its subsidiaries upheld (Supreme Court decision)

18 Sep - Italy: Draft law implementing Pillar Two global minimum tax

18 Sep - Sweden: Draft law implementing Pillar Two global minimum tax

15 Sep - Netherlands: Memorandum to parliament in response to report regarding bill implementing Pillar Two

13 Sep - EU: European Commission proposals for directives on business income taxation framework (BEFIT) and transfer pricing

12 Sep - KPMG report: Estimating an arm’s length range for North American retailers

7 Sep - Nigeria: Country-by-country reporting rules not validly adopted and thus unenforceable (Tax Appeal Tribunal decision)

5 Sep - Greece: Updated procedure for advance pricing agreements

5 Sep - UK: HMRC guidance on advance pricing agreements

4 Sep - Switzerland: Constitutional amendment empowering government to implement Pillar Two global minimum tax

1 Sep - KPMG report: Comments on public consultation document on Amount B under Pillar One following outcome statement on BEPS 2.0

1 Sep - Seychelles: Changes to transfer pricing rules

August 2023

30 Aug - Portugal: Public country-by-country reporting legislation approved

29 Aug - Finland: Public consultation on implementation of Pillar Two global minimum tax rules

29 Aug - Netherlands: Draft legislation implementing public country-by-country reporting

25 Aug - KPMG report: Potential U.S. tax implications of proposed Bermuda corporate income tax

23 Aug - Israel: Guidance on competent authority, mutual agreement, and bilateral APA procedures

21 Aug - Korea: Proposed amendments to transfer pricing and Pillar Two rules

15 Aug - Australia: Targeted consultation on implementation of Pillar Two global minimum tax rules

14 Aug - Canada: Draft legislation includes Pillar Two rules and revised DST and EIFEL rules

14 Aug - KPMG report: Accelerated competent authority procedure can extend MAP resolutions to subsequent years

10 Aug - Korea: Tax reform proposal for 2023, changes to Pillar Two and transfer pricing documentation rules

10 Aug - Luxembourg: Draft law implementing Pillar Two global minimum tax

9 Aug - Bermuda: Implementation of corporate income tax within scope of Pillar Two global minimum tax rules

7 Aug - Australia: Audit on ATO’s management of transfer pricing for related-party debt

4 Aug - Belgium: Overview of APA system

4 Aug - Croatia: Implementation of public country-by-country reporting

4 Aug - EU: Formal notice to 14 member states of failure to implement public country-by-country reporting

4 Aug - Ireland: Feedback statement on implementation of Pillar Two global minimum tax

3 Aug - KPMG report: Amount B and tax certainty

2 Aug - South Africa: Proposed APA program

July 2023

31 Jul - EU: Public country-by-country reporting implementation summary

31 Jul - KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on Canada and Mexico

25 Jul - KPMG report: OECD’s effort to simplify transfer pricing

25 Jul - KPMG report: New guidance on Pillar Two rules, initial observations and analysis

25 Jul - KPMG report: Public consultation on Amount B under Pillar One, initial observations

24 Jul - UK: Transfer pricing records regulations published

21 Jul - Korea: Payments treated as expenses under cost sharing agreement and not royalties (Administrative Court decision)

20 Jul - KPMG report: Latest Pillar Two guidance provides some relief for U.S. multinationals, but concerns remain

19 Jul - KPMG report: Transfer pricing and stock-based compensation

17 Jul - OECD: Report on BEPS 2.0, including new guidance on Pillar Two rules

17 Jul - OECD: Public consultation document on Amount B under Pillar One following outcome statement on BEPS 2.0

14 Jul - Gibraltar: 2023 budget includes consultation on implementation of Pillar Two global minimum tax, stamp tax changes

13 Jul - France: New transfer pricing measures announced for 2024 Draft Finance Bill

13 Jul - Thailand: Guidance for taxpayers within scope of Pillar Two global minimum tax rules

12 Jul - EU: European Commission progress report on Pillar One

12 Jul - Germany: Draft bill implementing Pillar Two global minimum tax

12 Jul - Liechtenstein: Consultation on implementation of public country-by-country reporting

12 Jul - Netherlands: Proposed amendments to tax ruling policy

12 Jul - UK: HMRC removes requirement for UK companies to make annual country-by-country reporting notification

12 Jul - OECD: Outcome statement on BEPS 2.0

10 Jul - KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on Germany, the Netherlands, and Sweden

7 Jul - Brazil: Public consultation on new transfer pricing rules

6 Jul - Australia: Report on review of advance pricing agreement program

June 2023

29 Jun - Romania: Amendments to public country-by-country reporting rules

28 Jun - France: Implementation of public country-by-country reporting

28 Jun - Germany: Updated transfer pricing guidelines; U.S. agreement on automatic exchange of country-by-country reporting

28 Jun - Lithuania: Country-by-country reporting directive transposed into domestic law

27 Jun - Denmark: Public consultation on draft bill to implement Pillar Two global minimum tax

27 Jun - KPMG report: Europe, Middle East, and Africa (EMA) transfer pricing insights (June 2023)

26 Jun - Australia: Delay in implementation of public country-by-country reporting

26 Jun - KPMG report: Transfer pricing methods for asset management sub-advisers

26 Jun - UK: Consultation on transfer pricing, permanent establishment, and DPT rules

26 Jun - UK: Spring Finance Bill 2023, including Pillar Two global minimum tax rules, substantively enacted

26 Jun - UK: Draft guidance on Pillar Two global minimum tax rules published, comments requested

23 Jun - Chile: Extension of deadline for filing transfer pricing affidavits

23 Jun - Korea: Imputation of arm’s length interest on accounts receivable from foreign affiliate was reasonable (Tax Tribunal decision)

22 Jun - Australia: Tax authority relies on anti-avoidance rather than transfer pricing arguments in foreign related-party financing dispute (Federal Court decision)

22 Jun - Germany: Legislation to implement country-by-country reporting directive

21 Jun - KPMG reports: Transfer pricing considerations in mergers and acquisitions, focus on UK

21 Jun - Switzerland: Implementation of Pillar Two minimum tax approved by public vote

21 Jun - United States: JCT analysis of possible effects of Pillar Two global minimum tax adoption

20 Jun - KPMG report: Survey on application of control of risk and DEMPE frameworks, focus on France, Italy, and Spain

20 Jun - KPMG report: Transfer pricing considerations for ESG-related intangible assets

16 Jun - Norway: Draft legislation implementing Pillar Two minimum tax

15 Jun - Brazil: OECD-aligned transfer pricing rules signed by president

14 Jun - Denmark: Public country-by-country reporting legislation passed

13 Jun - Kenya: Declaration of related-party or controlled transactions on income tax company returns

13 Jun - Czech Republic: Proposed legislation introducing top-up tax, implementing EU directive on global minimum tax

12 Jun - KPMG report: Brazil’s proposed transfer pricing rules, implications for intercompany financial transactions

12 Jun - Hong Kong: Update on profits tax, BEPS 2.0, and e-filing

12 Jun - Canada: Consultation on proposed transfer pricing rules

8 Jun - Canada: Mutual agreement procedure (MAP) statistics for 2021

8 Jun - Liechtenstein: Consultation draft for implementation of Pillar Two global minimum tax

8 Jun - Luxembourg: European Commission erred in finding grant of State aid based on OECD Transfer Pricing Guidelines (CJEU Advocate General opinion)

7 Jun - KPMG report: Transfer pricing implications of automotive innovation

6 Jun - France: New proposals to counter international tax fraud, including lower turnover threshold for transfer pricing documents

6 Jun - Switzerland: Consultation on draft law implementing Pillar Two global minimum tax

5 Jun - Netherlands: Bill implementing Pillar Two presented to Lower House of Parliament

2 Jun - Israel: Tax authority’s claim of deemed taxable transfer of functions, assets, and risks upheld (court decision)

1 Jun - Malaysia: Transfer pricing and advance pricing arrangement rules 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: Tax authority entitled to re-assess arm’s length interest rate on related-party loan (Tax Tribunal decision)

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 - India: Transfer pricing rules apply if counterparty becomes associated enterprise in same tax year (tribunal decision)

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 - OECD: Report to G20 Finance Ministers and Central Bank Governors, updates on developments in international tax reforms

24 Feb - South Africa: Proposed legislative framework for APAs in 2023 budget

23 Feb - Hong Kong: Tax measures in 2023-2024 budget include “patent box,” global minimum tax starting in 2025

20 Feb - Korea: Tax authority not entitled to select only certain local distributors for transfer pricing adjustment (Tax Tribunal decision)

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

14 Feb - KPMG report: Changes to Brazilian transfer pricing and royalty deduction rules, implications for U.S. multinationals

13 Feb - Sweden: Proposal for implementation of public country-by-country reporting

9 Feb - United States: Regulation under section 482 relating to consideration of foreign legal restrictions upheld (U.S. Tax Court)

9 Feb - KPMG report: Administrative guidance on the GloBE rules, focusing on issues of importance to U.S. companies

7 Feb - EU: Access to documents of EU Council working groups on public country-by-country reporting (EU General Court)

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

1 Feb - OECD: Manual on handling of mutual agreement procedures (MAPs) and advance pricing arrangements (APAs)

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

25 Jan - Netherlands: Guidance on rule to combat transfer pricing mismatches in context of capital contributions

24 Jan - OECD: Comments on public consultation document on withdrawal of DSTs under Pillar One

24 Jan - OECD: New methodology for Action 14 peer reviews, changes to MAP statistics reporting and new APA statistics reporting

23 Jan - Hungary: Changes to transfer pricing rules, including reporting and documentation

23 Jan - KPMG report: Focus on country-by-country reporting (CbC) data with Pillar Two minimum tax and public CbC reporting

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

9 Jan - UK: New transfer pricing documentation requirements, but delay of summary audit trail (SAT) pending public consultation

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 - KPMG report: Public consultation document under Pillar One on draft multilateral convention provisions on DSTs

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

20 Dec - OECD: Public consultation documents on withdrawal of DSTs under Pillar One, implementation under Pillar Two

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 - Israel: Tax authority’s intangible property valuation upheld due to insufficient and inconsistent taxpayer documentation (court decision)

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 - Germany: Law on DAC7, submitting transfer pricing documentation in tax audits, adopted by lower house of Parliament

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

18 Nov - Korea: Transfer pricing adjustments with respect to subsidiary loan and subsidiary performance guarantees affirmed (High Court decision)

17 Nov - UK: Autumn statement includes transfer pricing documentation changes, update on implementation of Pillar Two, increases in corporation tax and DPT rates

17 Nov - Germany: Updated guidance on application of arm’s length principle to cross-border transfers of functions

17 Nov - OECD: Aggregated country-by-country reporting data

16 Nov - OECD: Comments on progress report on administration and tax certainty aspects of Amount A of Pillar One

16 Nov - United States: Year-end tax discussion ideas for international tax and transfer pricing

15 Nov - Hungary: Proposed amendments to advance pricing arrangement rules and introduction of public country-by-country (CbC) reporting

14 Nov - Montenegro: Guidance under new transfer pricing rules

11 Nov - KPMG report: Comments on progress report on administration and tax certainty aspects of Amount A of Pillar One

11 Nov - UK: Implications of interest rate increases for transfer pricing

8 Nov - Luxembourg: Finding of illegal State aid involving application of arm’s length principle set aside (CJEU judgment)

3 Nov - Germany: Draft legislation to implement public country-by-country reporting; update on Pillar Two implementation

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 - Cyprus: Clarification on bilateral Competent Authority Arrangement for exchange of CbC reports with United States

20 Oct - Germany: Penalties for failure to comply with the obligation to keep or provide transfer pricing documentation compatible with EU law (CJEU judgment)

20 Oct - OECD: Report to G20 Finance Ministers and Central Bank Governors, updates on developments in international tax reforms

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

18 Oct - Korea: Transfer pricing adjustments added to customs value of imported goods when directly related (Supreme Court decision)

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

6 Oct - OECD: Progress report on administration and tax certainty aspects of Amount A of Pillar One; public consultation

6 Oct - EU: Report on EU Parliament meeting with European Commissioner; discussion of solidarity contribution on surplus profits in fossil sector, minimum tax directive

4 Oct - Philippines: Guidelines and procedures for requesting MAP

3 Oct - KPMG report: In defense of the arm’s length principle

July 2022

29 Jul - Lithuania: Changes to APA rules

26 Jul - KPMG report: Amount B—the forgotten piece of the Pillar One jigsaw

26 Jul - Poland: No transfer pricing documentation or Local file reporting obligation on contribution to foreign company’s supplementary capital

25 Jul - UK: New transfer pricing documentation rules effective for accounting periods beginning on or after 1 April 2023

22 Jul - Ireland: BEPS 2.0 implications for aviation sector

20 Jul - UK: Draft legislation to implement Pillar Two published

19 Jul - Germany: “Transfer of functions” proposal to align arm’s length principle with OECD Transfer Pricing Guidelines

18 Jul - KPMG report: The diverging paths of Pillars One and Two

18 Jul - Czech Republic: Tax priorities of the Czech EU Presidency

15 Jul - Germany: Proposals regarding transfers of functions, transfer pricing documentation, transposition of DAC7

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

8 Jul - United States: IRS releases PLR, granting consent to taxpayer’s request regarding cost-sharing arrangement and intangible development costs

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 - Netherlands: Allocation of debt and equity to PE, other transfer pricing issues (appellate court decision)

1 Jul - KPMG report: Environmental, social, and governance (ESG) and transfer pricing

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