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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

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

August 2016

31 Aug - Germany: Transfer pricing rules requiring adjustment on cross-border arrangements referred to CJEU

31 Aug - Poland: Tax authorities continue to focus on transfer pricing

30 Aug - Ireland: EC state aid investigation, “illegal tax benefits” to multinational company of €13 billion

25 Aug - Poland: Cash-pooling arrangements are loans, transfer pricing documentation rules apply

25 Aug - Poland: Increased number of transfer pricing audits, increased assessments

24 Aug - U.S. Treasury “white paper” on EC’s state aid investigations of transfer pricing rulings

24 Aug - OECD: Comments on proposed amendments, OECD Transfer Pricing Guidelines

22 Aug - Liechtenstein: Automatic exchange of country-by-country reporting

19 Aug - Asia Pacific: Transfer pricing review (2016 supplement)

18 Aug - Czech Republic: Automatic exchange of APAs, country-by-country reporting proposals

16 Aug - India: Application of Berry ratio, transfer pricing methodology

16 Aug - Israel: Country-by-country reporting, transfer pricing documentation in budget plan

16 Aug - Hong Kong: Management fee, head office recharge arrangements under scrutiny

16 Aug - Turkey: New transfer pricing rules enacted, aligned with OECD guidelines

15 Aug - Greece: Transfer pricing documentation deadline is extended

11 Aug - Nigeria: Country-by-country reporting, implementation moves forward

10 Aug - Australia: Amnesty for voluntary disclosure of offshore hub-related tax risks; transfer pricing implications

9 Aug - Canada: Discussion, observations about country-by-country reporting proposal

9 Aug - Germany: Loan guarantees by German parent company, for foreign subsidiaries

8 Aug - Asia Pacific: Country-by-country reporting, status update for region

8 Aug - EU: Country-by-country reporting—an EU perspective

5 Aug - Australia: Review of transfer pricing developments since 2012; plans for more changes

5 Aug - Luxembourg: Draft law for country-by-country reporting submitted to Parliament 

5 Aug - India: No transfer pricing referral, when taxpayer claims no “international transactions”

5 Aug - India: Taxpayer allowed to change from TNMM to CUP during proceedings

3 Aug - Canada: Country-by-country reporting requirements in draft legislative proposals

1 Aug - Korea: Revised legislation, transfer pricing and country-by-country reporting rules

July 2016

29 Jul - Mexico: Transfer pricing measures in tax legislation

26 Jul - India: Transfer Pricing Officer’s authority to examine arm’s length price

25 Jul - Austria: New transfer pricing documentation, country-by-country rules effective for 2016

25 Jul - OECD: Report on status of BEPS project

21 Jul - Czech Republic: Regional courts reject basis for transfer pricing assessments

18 Jul - U.S. Tax Court: Newspaper’s motion to intervene in cost-sharing arrangement case held in abeyance

15 Jul - Hong Kong: Transfer pricing and offshore tax regimes

14 Jul - India: Taxpayer must have opportunity to cross-examine comparable companies’ personnel

13 Jul - China: Transfer pricing documentation, related-party reporting guidance from BEPS project

11 Jul - Hong Kong: BEPS participation, recommendations pending government action

8 Jul - India: Valuation of intangibles; only future projections, no hindsight allowed

7 Jul - OECD: Discussion draft under BEPS Actions 8-10, profit split guidance 

7 Jul - OECD: Discussion draft under BEPS Action 7, profits attributed to
permanent establishments

6 Jul - Hong Kong: Transfer pricing and BEPS considerations—intangible property and R&D activities

6 Jul - Sweden: Revising an agreement’s conditions to arm’s length terms

5 Jul - Belgium: Country-by-country reporting, transfer pricing documentation; new law is published

5 Jul - India: No transfer pricing adjustment; license agreement with U.S. company

4 Jul - Japan: Guidance under new transfer pricing documentation rules

4 Jul - OECD: BEPS discussion drafts include revised guidance on profit splits

4 Jul - OECD: Comments invited on revised transfer pricing guidelines

1 Jul - Germany: Country-by-country reporting, BEPS items in draft bill

OECD: Comments invited on revised transfer pricing guidelines

OECD: Comments invited on revised transfer pricing guidelines

OECD: Comments invited on revised transfer pricing guidelines

May 2016

25 May - Australia: Country-by-country, final Local files released

25 May - Norway: Transfer pricing documentation, country-by-country reporting included in political agreement

24 May - Latvia: Compensating adjustments and transfer prices

24 May - Sweden: Commentary on transfer pricing documentation, country-by-country legislative proposals

23 May - United States: Senators again express concerns about EC state-aid investigations

23 May - Denmark: Transfer pricing adjustment statistics, trends and

20 May - EU: “State aid” and transfer pricing rulings

19 May - Denmark: New transfer pricing documentation requirements

19 May - Austria: Proposed legislation, transfer pricing documentation and country-by-country reporting

16 May - Belgium: Draft law, country-by-country reporting and transfer pricing documentation requirements

13 May - Czech Republic: Transfer pricing examination trends

13 May - Norway: Proposed legislation to implement country-by-country reporting rules

12 May - OECD: Canada, Iceland, India, Israel, New Zealand, China advance country-by-country reporting

12 May - United States: IRS practice unit, taxpayer’s affirmative use of section 482

11 May - Peru: New forms for transfer pricing declarations

10 May - Hungary: Transfer pricing measures in tax legislative proposals

10 May - India: No transfer pricing adjustment for advertising, marketing, and promotion

3 May - Sweden: Proposed legislation, transfer pricing documentation and
country-by-country reporting exchange

March 2016

31 Mar - United States: APMA program, APA statistics for 2015

31 Mar - Korea: Master file and local file templates are released

28 Mar - UK: BEPS items included Finance (No. 2) Bill 2016 

24 Mar - OECD: Treaty benefits for non-CIV funds; BEPS follow-up consultation 

23 Mar - Canada: Country-by-country reporting, transfer pricing proposals in 2016 federal budget

23 Mar - EU: Draft proposal on “public” country-by-country reporting

22 Mar - India: No aggregation of transactions for benchmarking in “unusual” circumstances

22 Mar - OECD: Standardized electronic format for exchanging country-by-country reports

21 Mar - United States: IRS “practice unit” on inbound resale price method, routine distributor

18 Mar - Turkey: Draft communiqué on transfer pricing documentation, country-by-country reporting

16 Mar - Indonesia: FAQs on transfer pricing

14 Mar - India: New guidelines for transfer pricing referrals

14 Mar - United States: IRS “practice unit” on interest expense limitation under section 163(j), related-party debt

11 Mar - UK: Preparing for country-by-country reporting

10 Mar - Nigeria: Transfer pricing comparable data constraint—issues, implications

9 Mar - Australia: Costs of non-compliance with country-by-country reporting requirements

8 Mar - EU: Automatic exchange of country-by-country reporting by multinational companies

Mar 8 - India: Brand-promotion expenses not “international transaction” for arm’s length standard

7 Mar - United States: Treasury responds to Congress, EU state-aid “tax ruling” investigations

7 Mar - United States: IRS "practice unit," residual profit split method, outbound

4 Mar - Poland: Enhanced tax audit focus on transfer pricing

4 Mar - United States: IRS “practice unit,” transfer pricing documentation by outbound taxpayers

3 Mar - UK: Final country-by-country reporting regulations

3 Mar - EU: State-aid investigations of “tax rulings,” response to U.S. concerns

2 Mar - Dominican Republic: Amount triggering transfer pricing regime, related-party transactions (2016) 

1 Mar - India: Country-by-country reporting, transfer pricing documentation rules in budget 2016

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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