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Recent Articles
August 2024
23 Aug - Australia: Proposed amendments to legislation implementing Pillar Two global minimum tax rules
21 Aug - KPMG report: Potential effects on businesses of new UN tax treaty
19 Aug - Channel Islands: Pillar Two draft legislation published (Jersey)
16 Aug - KPMG report: Reassessing operations in Mexico due to maquila tax regime changes
12 Aug - OECD: Transfer pricing framework for lithium
8 Aug - Austria: Amendments to Pillar Two draft legislation and loss carryforward rules published
8 Aug - Turkey: Draft legislation implementing Pillar Two submitted to Parliament
6 Aug - Korea: Further proposed amendments to Pillar Two rules
5 Aug - Australia: Senate committee report on public country-by-country reporting bill
2 Aug - EU: Public consultation on template and formats for public country-by-country reports
July 2024
29 Jul - Mexico: Updated qualified maquiladora approach applies to APAs for 2020 to 2024
25 Jul - UN: Revised draft terms of reference for UN framework convention on international tax cooperation
22 Jul - KPMG report: APMA program annual report on APA statistics in the United States for 2023
22 Jul - KPMG report: Employee data reporting under Pillar Two
16 Jul - Italy: Decree on Pillar Two global minimum tax
16 Jul - OECD: Negotiations on Pillar One multilateral convention continue
12 Jul - OECD: Consultation on GloBE information return filing standard
11 Jul - Israel: Adjusted intellectual property (IP) valuation (District Court decision)
11 Jul - KPMG report: Transfer pricing in Brazil
9 Jul - Australia: Changes to non-arm’s length income provisions for superannuation funds
3 Jul - Gibraltar: Additional tax proposals in 2024 budget, including update to Pillar Two rules
1 Jul - Australia: ATO update on implementation of Pillar Two global minimum tax rules
1 Jul - KPMG report: Taxpayer-initiated transfer pricing adjustments in MAP
June 2024
28 Jun - Finland: Public country-by-country reporting implemented
28 Jun - Italy: Draft legislation implementing public country-by-country reporting
28 Jun - Malta: Public country-by-country reporting implemented
28 Jun - Norway: Consultation on implementation of Pillar Two UTPR
25 Jun - KPMG report: Accounting for income tax implications of Pillar Two GloBE top-up taxes
24 Jun - EU: ECOFIN report addressing FASTER, “Unshell,” transfer pricing, and BEFIT directives
20 Jun - KPMG report: Further guidance on Pillar Two GloBE model rules
20 Jun - KPMG report: New Amount B guidance expands on definitions
20 Jun - Luxembourg: Draft law amending Pillar Two law introduced to Parliament
18 Jun - KPMG report: OECD unveils further details on Amount B simplified approach
17 Jun - OECD: Further guidance on Pillar One Amount B and Pillar Two global minimum tax
11 Jun - Cyprus: Quality assurance review template for Local file
6 Jun - Australia: Public country-by-country reporting legislation introduced
5 Jun - Germany: Consultation on draft tax return for Pillar Two purposes
5 Jun - OECD: Updated International Compliance Assurance Programme (ICAP) FAQs
5 Jun - Serbia: Rulebook on arm’s length interest rates for 2024
4 Jun - Italy: Implementation of Pillar Two transitional safe harbors
May 2024
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 - 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 - 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
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 - 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
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 - 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
11 Mar - Italy: Transfer pricing requirements for investment manager exemption
5 Mar - Poland: Bill implementing Pillar Two global minimum tax
February 2024
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 - Singapore: Tax measures in budget 2024 include Pillar Two global minimum tax rules
19 Feb - OECD: Report on Amount B under Pillar One
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
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 - 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 - KPMG report: Comments on European Commission consultation on transfer pricing initiative
10 Jan - Korea: Amendments to Pillar Two rules enacted
4 Jan - Qatar: Extended deadline for country-by-country reports and notifications
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
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 - Moldova: Public country-by-country reporting implemented
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
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”
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 - 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 - Malaysia: Finance Bill (No. 2) 2023 includes proposed Pillar Two rules
6 Nov - Sweden: Updated draft legislation implementing Pillar Two global minimum tax
October 2023
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 - Romania: Proposed legislation implementing Pillar Two global minimum tax
20 Oct - Ireland: Tax proposals in Finance bill 2023 include implementation of Pillar Two global minimum tax
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
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
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
20 Sep - OECD: Comments on public consultation document on Amount B under Pillar One
20 Sep - Kenya: Public consultation on draft transfer pricing rules
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
12 Sep - KPMG report: Estimating an arm’s length range for North American retailers
5 Sep - Greece: Updated procedure for advance pricing agreements
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
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
July 2023
31 Jul - EU: Public country-by-country reporting implementation summary
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
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
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 - OECD: Outcome statement on BEPS 2.0
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 - 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
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: 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
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
7 Jun - KPMG report: Transfer pricing implications of automotive innovation
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
1 Jun - Malaysia: Transfer pricing and advance pricing arrangement rules 2023
May 2023
30 May - KPMG report: Practical transfer pricing compliance in a complex world
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
5 Apr - Nigeria: Statement regarding possible implementation of Pillar Two global minimum tax rules
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
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