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Transfer Pricing

Transfer Pricing

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

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>> Go to the BEPS Action 13: Latest country implementation update

July 2018

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

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

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

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

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

20 Jul - Poland: Proposed changes to transfer pricing rules

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

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

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

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

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

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

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

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

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

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

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

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

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

March 2018

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

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

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

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

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

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

21 Mar - EU: Proposals for taxation of digital businesses

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

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

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

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

16 Mar - Singapore: Discussion of revised transfer pricing guidelines

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

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

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

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

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

7 Mar - EU: Aggressive tax planning; focus on interest, royalties, transfer pricing

6 Mar - Mauritius: Country-by-country reporting regulations, effective July 2018

6 Mar - Malaysia: Updated form for cross-border transactions, transfer pricing risk assessments

January 2018

30 Jan - Jamaica: Transfer pricing declaration, file with income tax return

29 Jan - Australia: Country-by-country reports, Master and Local files due 15 February 2018, Australian taxpayers with December year-end

24 Jan - OECD: Multilateral risk assessment pilot program, transfer pricing information

23 Jan - Sweden: Timing of data, information to test benchmarking analysis for arm’s length pricing

22 Jan - Australia: ATO guideline on cross-border related-party financing arrangements, transactions

22 Jan - Belgium: Taxpayers can expect busy transfer pricing years ahead, following new three-layered approach applied by Belgian tax authorities

18 Jan - United States: Updated FAQs, information about country-by-country reporting

17 Jan - Brazil: Changes to “tax haven” and “privileged tax regimes” lists, implications for applying transfer pricing rules

16 Jan - United States: LB&I directives on transfer pricing examinations

16 Jan - Denmark: New deadlines for preparing, submitting transfer pricing documentation

9 Jan - Taiwan: Safe harbor exemption, Master file and country-by-country reporting submissions

8 Jan - India: First bilateral APA signed with United States

5 Jan - Thailand: Cabinet approves transfer pricing measures, with amendments

5 Jan - France: Transfer pricing documentation measures included in new law

5 Jan - Malaysia: Country-by-country reporting update

3 Jan - Argentina: Transfer pricing rules reformed, revised

3 Jan - EU: Retroactive transfer pricing adjustments and EU customs valuation

2 Jan - Hong Kong: BEPS legislation, move towards enhanced transfer pricing enforcement regime

2017 Articles

December 2017

26 Dec - China: Guidance clarifying country-by-country reporting, information exchange

22 Dec - Austria: Country-by-country reporting by year-end

22 Dec - India: Aggregation of IT services provided to related parties, single composite contract

21 Dec - Switzerland: Country-by-country reporting for FY 2016, filing is due 31 December 2017

21 Dec - Malaysia: Reminder of approaching country-by-country reporting notification deadline

21 Dec - OECD: Jurisdictions implement final regulations for first filings of country-by-country reports

20 Dec - France: Country-by-country reporting; transitional measure announced by French tax authorities

18 Dec - Netherlands: EC state-aid investigations, whether tax rulings provide “unfair advantage”

18 Dec - Germany: Transfer pricing adjustments for non-arm’s length transactions with non-resident related companies, CJEU Advocate General’s opinion confirms

15 Dec - Hungary: Country-by-country reporting and notification requirements, deadlines

14 Dec - Czech Republic: Binding rulings, determining tax base of permanent establishments available in 2018

14 Dec - Czech Republic: Review of first-phase common errors, country-by-country reporting

13 Dec - Canada: Country-by-country reports due 31 December 2017

13 Dec - New Zealand: BEPS implementing legislation would affect related-party loans, transfer pricing rules

12 Dec - Italy: Deadline for filing country-by-country reports postponed

11 Dec - Greece: Guidelines for country-by-country reports

8 Dec - South Africa: Country-by-country reporting returns, due date extended

4 Dec - OECD: First review of BEPS Action 5 minimum standard, spontaneous exchange on tax rulings

1 Dec - Italy: Implementing guidelines for country-by-country reports

November 2017

30 Nov - OECD: Updated guidance on country-by-country reporting (BEPS Action 13)

28 Nov - Thailand: Update on transfer pricing proposals

27 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2016

23 Nov - Australia: ATO grants extension of time to file country-by-country statements

22 Nov - Taiwan: Transfer pricing documentation to include country-by-country reporting, Master file

21 Nov - United States: IRS practice units, common ownership or control under Code section 482

21 Nov - Romania: Guidance on form for country-by-country reporting

21 Nov - United States: IRS update to jurisdiction status table, country-by-country reporting

20 Nov - Peru: Transfer pricing documentation—country-by-country reporting, Master file, Local file

17 Nov - UK: New corporate interest restriction rules intersect with transfer pricing

15 Nov - Canada: APA statistics for 2016

8 Nov - United States: IRS practice units on APAs for tangible goods transactions

8 Nov - WCO: Case study; transfer pricing documentation and customs valuation

7 Nov - Costa Rica: Country-by-country reporting, draft resolution released

6 Nov - OECD: Updated transfer pricing profiles from 31 countries

3 Nov - Hungary: Transfer pricing documentation requirements updated, including arm’s length pricing

3 Nov - Italy: Agreement for automatic exchange of country-by-country reports with United States

2 Nov - India: Final rules on country-by-country reporting, Master file requirements

1 Nov - Bulgaria: Country-by-country reporting procedure, format approved

October 2017

31 Oct - India: Unilateral APA addresses marketing, trading, and assembly activities

27 Oct - India: Unilateral APA with taxpayer in travel sector

26 Oct - India: First country-by-country report due date extended to 31 March 2018

25 Oct - OECD: Public consultation on 1 November, tax challenges of digitalisation

20 Oct - Hungary: Country-by-country reporting form, released by tax authority

20 Oct - OECD: Public consultations on transfer pricing matters

18 Oct - OECD: Comments to tax challenges of digitalization (BEPS Action 1)

18 Oct - Poland: Country-by-country reporting, template of electronic form available

13 Oct - Kosovo: Annual report (2016) of controlled transactions due 30 November

12 Oct - Finland: Guidance concerning intra-group services, determining arm’s length mark-up

11 Oct - Czech Republic: Country-by-country reporting implemented

11 Oct - OECD: Country-by-country reporting implementation status, exchange relationships (BEPS Action 13)

11 Oct - Poland: Decree on information to include in transfer pricing documentation

10 Oct - EU: New rules, process for resolving tax treaty-related disputes

10 Oct - Greece: Country-by-country reporting update

9 Oct - India: Proposed country-by-country reporting, Master file rules

6 Oct - OECD: Comments on BEPS discussion drafts, attribution of profits to permanent establishments and transactional profit splits

5 Oct - Vietnam: Transfer pricing audits of related-party royalty, service fee payments

5 Oct - Luxembourg: Transfer pricing rulings granted multinational entity group; EC state aid investigation

5 Oct - Malaysia: Country-by-country reporting guidance

3 Oct - Switzerland: Country-by-country reporting ordinance effective 1 December 2017; voluntary reporting begins 1 November

2 Oct - KPMG report: Common-sense transfer pricing compliance in a BEPS world

August 2017

30 Aug - United States: List of countries for country-by-country reporting data exchanges 

30 Aug - Australia: Interaction between ATO and multinational companies; corporate tax avoidance inquiry includes focus on transfer pricing rules

29 Aug - Taiwan: Country-by-country reporting requirements in draft transfer pricing documentation rules

22 Aug - Country-by-country reporting: Timeline of notification requirements per country

22 Aug - Australia: Practical experiences on filing Part A of Australian Local files for some “significant global entities”

21 Aug - Australia: Taxpayer withdraws appeal; transfer prices and related-party loans

18 Aug - UK: Updated HMRC guidance for filing country-by-country reports

17 Aug - Bulgaria: Rules for country-by-country reporting

17 Aug - Greece: Country-by-country reporting measures are enacted

14 Aug - Latvia: Transfer pricing reporting requirements include country-by-country reports

11 Aug - United States: IRS now accepting country-by-country report (Form 8975)

7 Aug - Kosovo: Transfer pricing requirements, documentation rules

4 Aug - New Zealand: Update on BEPS, transfer pricing proposals

2 Aug - India: Foreign exchange fluctuation gain or loss, operating income and arm’s length pricing

1 Aug - Hong Kong: Transfer pricing legislation expected by late 2017; findings of BEPS consultation

1 Aug - India: Country-by-country reporting, update

1 Aug - OECD: Draft toolkit, addressing taxation of offshore indirect transfers of assets

June 2017

30 Jun - United States: Form 8975 and instructions for country-by-country reporting; IRS launches CbC webpage

29 Jun - Thailand: Transfer pricing regime pending public comments, final steps

28 Jun - India: APA concerning severance pay to information technology-enabled service employees

27 Jun - KPMG report: Discussion draft, BEPS Action 10 revised guidance on profit splits

23 Jun - Italy: Transfer pricing rules are revised

23 Jun - Romania: Country-by-country reporting added to tax law

22 Jun - OECD: Toolkit for “developing countries” to address lack of comparables for transfer pricing analyses

22 Jun - OECD: BEPS inclusive framework, update on country-by-country reporting exchanges (including update for United States)

22 Jun - OECD: BEPS discussion drafts, attribution of profits to permanent establishments and transactional profit splits

21 Jun -  Canada: New exchange arrangement with United States, to implement country-by-country reporting standard

21 Jun - EU: Proposed mandatory disclosure of reportable tax planning cross-border arrangements

20 Jun - India: Notional interest on “deemed advances” involving transfer pricing adjustments of related parties

19 Jun - India: Tribunal rejects internal comparables, but looks to comparability factors of location, value chain, product utility

19 Jun - UK: Country-by-country reporting, notification to HM Revenue & Customs

16 Jun - Russia: Status of country-by-country reporting, transfer pricing documentation proposals 

12 Jun - Costa Rica: Time for filing transfer pricing returns is extended

9 Jun - India: Revised “safe harbour rules” focus on transfer pricing disputes

7 Jun - Azerbaijan: Transfer pricing rules introduced; effective for 2017

7 Jun - India: Evaluating advertising and marketing promotion expenses as international transaction

6 Jun - Colombia: Transfer pricing regime, rules for controlled foreign corporations

6 Jun - Hungary: Country-by-country reporting approved by parliament

May 2017

30 May - OECD: Initial impressions about discussion draft, hard-to-value intangibles

30 May - Pakistan: Transfer pricing audit, penalty provisions in budget 2017

30 May - Turkey: Transfer pricing provisions and country-by-country reporting rules

26 May - KPMG report: Potential ripple effects of BEPS reforms, beyond tax issues

25 May - India: Expense reimbursements not taxable; transfer pricing study showed no profit element

24 May - Israel: Update on status of country-by-country reporting

23 May - OECD: Discussion draft, guidance on hard-to-value intangibles

22 May - India: Excluding cost reimbursements from related parties (without mark-up) from operating costs

22 May - India: Export commission paid to related party not a royalty; transfer pricing adjustment rejected

18 May - Australia: Related-party financing arrangements, analysis

18 May - France: Country-by-country reporting notification and filing requirements

17 May - India: Brand development not separate international transaction, warranting transfer pricing adjustment

16 May - Australia: ATO draft guidance on related-party financing arrangements 

16 May - Czech Republic: Update on transfer pricing assessments

11 May - Korea: Update on country-by-country reporting, transfer pricing rules

9 May - India: Convertible loans, loan guarantees for foreign related parties

9 May - Singapore: Cost-plus mark-up basis available for service companies, providing routine services to related parties

8 May - Norway: Proposed earnings stripping rule changes; interest paid to related parties

8 May - UK: Group ratio method and related parties, possible corporate
interest restriction

5 May - India: Report of APA statistics

4 May - OECD: Country-by-country reporting implementation status; exchange relationship between tax administrations

January 2017

27 Jan - UK: Revised HMRC guidance, no transfer pricing discussions outside APAs

26 Jan - Indonesia: New transfer pricing requirements include country-by-country reporting

25 Jan - OECD: Helping developing countries with comparables for transfer pricing analyses

24 Jan - Belgium: Transfer pricing documentation

24 Jan - Nigeria: Transfer pricing forms for 2017

20 Jan - Australia: ATO guidance on related-party marketing hubs

19 Jan - India: Loss-making companies as comparables

19 Jan - United States: IRS guidance on country-by-country report filing process

16 Jan - Australia: Q&As on country-by-country reporting

16 Jan - Singapore: Updated transfer pricing guidelines released

14 Jan - Peru: Transfer pricing legislation reflects OECD recommendations

12 Jan - United States: Draft Form 8975 for country-by-country reporting

11 Jan - Brazil: Certain Austrian holding companies identified as “privileged tax regime”

10 Jan - Cyprus: Decree adopting country-by-country reporting; notification extended to October 2017

6 Jan - Malaysia: Final rules on annual country-by-country reporting

5 Jan - Dominican Republic: Update of “white list” countries, transfer pricing implications

4 Jan - United States: IRS practice unit, section 367(d) transactions and cost sharing arrangments

3 Jan - Brazil: Country-by-country reporting rules

3 Jan - Chile: Country-by-country reporting required in new transfer pricing affidavit

3 Jan - Korea: Country-by-country reporting, transfer pricing reporting proposed changes

October 2016

28 Oct - Hong Kong: Consultation on formal transfer pricing regime

28 Oct - OECD: Automatic exchange of tax information agreement, signed by Cook Islands

25 Oct - Channel Islands: Country-by-country reporting, draft regulations in Jersey

24 Oct - Singapore: Country-by-country reporting guide

21 Oct - Ireland: Irish Revenue updates FAQs on country-by-country reporting

21 Oct - OECD: Five jurisdictions agree to automatic exchange of country-by-country reports

21 Oct - Vietnam: Draft decree to implement transfer pricing standards, BEPS recommendations

20 Oct - Ireland: Transfer pricing considerations of centralised procurement strategies

18 Oct - China: New APA administrative guidelines, effective December 2016

18 Oct - India: Implications of APA on pre-rollback transactions

18 Oct - India: Transfer pricing implications of loan guarantee, working capital loans furnished related parties

18 Oct - India: Transfer pricing not applicable to transactions with foreign branch office

14 Oct - United States: IRS position on unilateral APA applications involving maquiladoras

14 Oct - Luxembourg: Budget proposals, to transpose arm’s length principle, transfer pricing analysis

14 Oct - UK: Practical issues that businesses may face concerning country-by-country reporting

13 Oct - Australia: Involving human resources, mobility professionals in country-by-country reporting 

11 Oct - India: Arm's length interest rate on related-party borrowings

11 Oct - India: Effects of customs duty, air freight, currency fluctuation adjustments on arm’s length price

10 Oct - France: Decree implementing country-by-country reporting

Transfer Pricing Review (2015)

Transfer Pricing Review provides transfer pricing information for almost 100 countries, including documentation requirements, deadlines, transfer pricing methods, penalties, special considerations, advance pricing agreements, and competent authority matters.

Read more >

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