KPMG's global editions of TaxNewsFlash are maintained and distributed by KPMG in the United States. When you click the hyperlinks below, you will be directed away from this page owned by KPMG International and redirected to a page owned by KPMG in the United States.  

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

June 2022

29 Jun - Australia: Proposed amendments to thin capitalisation rules, effect on arm's length debt test

28 Jun - Malta: Update on transfer pricing landscape

27 Jun - UK: Background and implications of delayed implementation of Pillar Two

21 Jun - France: Multinational entity agrees to pay over €1.245 billion to resolve cross-border controversy

21 Jun - Cambodia: Guidance regarding loans between related parties; interest rate and supporting documentation

20 Jun - EU: Report of ECOFIN to European Council on tax issues including Pillar Two, minimum tax, harmful tax practices, preferential tax regimes, non-cooperative jurisdictions

17 Jun - EU: Proposal for EU minimum tax directive; update after ECOFIN Council meeting

17 Jun - India: Updated guidance for mutual agreement procedure (MAP)

16 Jun - United States: Transfer pricing settlement initiative program for corporate taxpayers (New Jersey)

15 Jun - OECD: Comments on tax certainty aspects of Amount A under Pillar One

14 Jun - UK: Implementation of Pillar Two delayed

14 Jun - OECD: Tax transparency in Africa 2022

10 Jun - KPMG report: Comments on tax certainty aspects of Amount A under Pillar One

10 Jun - Luxembourg: Transfer pricing implications of new income tax treaty with UK

9 Jun - OECD: New transfer pricing country profiles for Egypt, Liberia, Saudi Arabia, and Sri Lanka

8 Jun - Peru: Approaching deadline for transfer pricing reports for FY 2021

7 Jun - KPMG report: Country-by-country reporting notifications, requirements per country

7 Jun - United States: Future of consumer and retail—transfer pricing perspective

6 Jun - Poland: Finance Minister’s reply to parliamentary inquiry regarding transfer pricing information

1 Jun - United States: Comments submitted to IRS regarding plans to update MAP and APA guidelines

May 2022

27 May - OECD: Tax certainty aspects of Amount A under Pillar One; public consultation

25 May - OECD: Comments on regulated financial services exclusion under Amount A of Pillar One

25 May - Hong Kong: Update on corporate tax issues, including transfer pricing documentation

24 May - EU: Status regarding proposal for EU minimum tax directive

23 May - Australia: Labor party wins 2022 election, tax policies include public country-by-country (CbC) reporting

20 May - KPMG report: Comments on regulated financial services exclusion under Amount A of Pillar One

20 May - China: Shenzhen launches first tax and customs collaborative transfer pricing management mechanism

16 May - KPMG report: Public consultation meeting on implementation framework of global minimum tax

11 May - Vietnam: Recommended focus on tax audit and inspection of high-risk industries and areas (transfer pricing)

10 May - Czech Republic: Additional tax assessment based on overall profitability for unrelated-party transactions (court decision)

9 May - Israel: Court decision on business restructuring and deemed transfer of business functions, assets and risks

9 May - Switzerland: Transfer pricing controversy statistics, including effects of COVID-19

6 May - Netherlands: Considerations for companies in scope of Pillar Two rules

6 May - New Zealand: Consultation on implementation of Pillar Two rules

6 May - OECD: Regulated financial services exclusion under Amount A of Pillar One; public consultation

5 May - KPMG report: BEPS 2.0 implementation considerations for Mexico

4 May - Nigeria: Summary of tax transparency reporting developments

4 May - OECD: Tax transparency in Latin America 2022

4 May - Poland: Transfer pricing reporting changes

3 May - OECD: Comments on extractives exclusion under Amount A of Pillar One

3 May - KPMG report: Comments on extractives exclusion under Amount A of Pillar One

3 May - KPMG report: Transfer pricing planning 2.0

3 May - KPMG report: Why operationalizing transfer pricing is more important than ever

3 May - Switzerland: Tax transparency reporting statistics and global minimum tax update

2 May - UK: Transfer pricing statistics (FY 2021)

April 2022

28 Apr - KPMG report: Transfer pricing and the audit committee agenda, implementation steps

26 Apr - United States: Country-by-country (CbC) report in the transfer pricing risk analysis process (IRS practice unit)

22 Apr - OECD: Comments on draft rules for domestic legislation on scope under Amount A of Pillar One

21 Apr - Kenya: Transfer pricing and other tax-related measures in Finance Bill, 2022

20 Apr - KPMG report: Comments on draft rules for domestic legislation on scope under Amount A of Pillar One

20 Apr - KPMG report: Transfer pricing and the audit committee agenda

20 Apr - Mexico: Considerations for maquiladora transfer pricing strategy, given elimination of APAs

20 Apr - Zimbabwe: Extended deadlines for corporate income tax and transfer pricing returns for 2021

14 Apr - KPMG report: Comments on implementation framework of global minimum tax

14 Apr - KPMG report: Comments in response to UK consultation on global minimum corporate tax

14 Apr - OECD: Comments on implementation framework of global minimum tax

14 Apr - OECD: Extractives exclusion under Amount A of Pillar One; public consultation

12 Apr - Brazil: Update on revisions to transfer pricing rules, steps toward OECD Transfer Pricing Guidelines

12 Apr - Zambia: Country-by-country reporting rules for 2021 tax year

11 Apr - Australia: Tax and transfer pricing implications of IBOR reform

11 Apr - Kenya: Proposed reporting requirements for multinational entities

11 Apr - Latvia: Implications of EU “public” country-by-country reporting for Latvian groups

5 Apr - EU: No agreement on revised proposal for minimum tax directive (ECOFIN Council meeting 5 April 2022)

4 Apr - OECD: Draft rules for domestic legislation on scope under Amount A of Pillar One; comments requested

1 Apr - Thailand: Extended deadline for filing transfer pricing disclosure form for 2020 (COVID-19)

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.