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The Organization for Economic Cooperation and Development (OECD) on October 5, 2015, released the final reports under the Base Erosion & Profit Shifting (BEPS) project.

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Transfer pricing alerts

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Transfer pricing alerts

Transfer pricing

Updates on transfer pricing developments around the world.

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Recent alerts and an archive of alerts from previous months appear below; for older issues, please email a request to globaltaxpublications@deloitte.com.

 

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Recent alerts

Transfer Pricing Alert - 2016-030

Austria's Transfer Pricing Documentation Act officially published (15 August 2016)

Transfer Pricing Alert - 2016-029

Luxembourg issues draft law on country-by-country reporting (8 August 2016)

Transfer Pricing Alert - 2016-028

Canada releases draft legislation on country-by-country reporting (5 August 2016)

Transfer Pricing Alert - 2016-027

Belgium finalizes mandatory transfer pricing reporting requirements (4 August 2016)

Transfer Pricing Alert - 2016-026

China's SAT issues new rules on reporting of related-party transactions and contemporaneous documentation (14 July 2016)

Transfer Pricing Alert - 2016-025

OECD releases discussion draft on revised guidance on profit splits (12 July 2016)

Transfer Pricing Alert - 2016-024

United States issues final country-by-country reporting regulations (1 July 2016)

Transfer Pricing Alert - 2016-023

OECD issues additional guidance on CbC reporting (1 July 2016)

Transfer Pricing Alert - 2016-022

Ireland introduces bilateral APA program (30 June 2016)

Transfer Pricing Alert - 2016-021

OECD approves incorporation of BEPS amendments into transfer pricing guidelines (17 June 2016)

Transfer Pricing Alert - 2016-020

In Medtronic, U.S. Tax Court rules against IRS's use of CPM, applies CUT method (14 June 2016)

Transfer Pricing Alert - 2016-019

Germany's draft tax law includes CbC measures (9 June 2016)

Transfer Pricing Alert - 2016-018

Austria plans introduction of standardized transfer pricing documentation (9 June 2016)

Transfer Pricing Alert - 2016-017

Denmark finalizes implementation of OECD three-tiered approach to transfer pricing documentation (11 May 2016)

Transfer Pricing Alert - 2016-016

European Commission proposes public disclosure of MNE’s tax information (25 April 2016)

Transfer Pricing Alert - 2016-015

2015 U.S. APA report shows interest in APAs has never been higher (13 April 2016)

Transfer Pricing Alert - 2016-014

Portugal introduces country-by-country reporting requirement (9 April 2016)

Transfer Pricing Alert - 2016-013

Turkey proposes adoption of country-by-country reporting requirement (7 April 2016)

Transfer Pricing Alert - 2016-012

Irish Revenue announce formal APA program (7 April 2016)

Transfer Pricing Alert - 2016-011

Belarus refines transfer pricing regulations (5 April 2016)

Transfer Pricing Alert - 2016-010

Canada announces proposed country-by-country reporting requirements (24 March 2016)

Transfer Pricing Alert - 2016-009

IRS issues three transfer pricing International Practice Units (16 March 2016)

Transfer Pricing Alert - 2016-008

Italy introduces country-by-country reporting requirement (10 March 2016)

Transfer Pricing Alert - 2016-007

UK issues country-by-country reporting regulations (9 March 2016)

Transfer Pricing Alert - 2016-006

U.S. Tax Court rules for IRS on question of aggregation in transfer pricing adjustment (8 March 2016)

Transfer Pricing Alert - 2016-005

IRS files notice of appeal in Altera case (23 February 2016)

Transfer Pricing Alert - 2016-004

IRS issues international practice units on transfer pricing topics (17 February 2016)

Transfer Pricing Alert - 2016-003

Ireland issues country-by-country reporting regulations (28 January 2016)

Transfer Pricing Alert - 2016-002

Japan's proposed adoption of BEPS Action 13 includes new prescriptive transfer pricing documentation rules (27 January 2016)

Transfer Pricing Alert - 2016-001

U.S. issues country-by-country reporting regulations (6 January 2016)

Archive

Transfer Pricing Alert - 2015-018

France takes steps toward implementation of country-by-country (12 November 2015)

Transfer Pricing Alert - 2015-017

BEPS Final Report Updates Scope of Work for Guidance on Profit Splits (15 October 2015)

Transfer Pricing Alert - 2015-016

OECD Releases Final BEPS Reports (6 October 2015)

Transfer Pricing Alert - 2015-015

IRS Issues Temporary Regulations on Coordination Between Sections 482 and 367 (17 September 2015)

Transfer Pricing Alert - 2015-014

IRS Releases New Competent Authority Revenue Procedure (31 August 2015)

Transfer Pricing Alert - 2015-013

IRS Releases Advance Pricing Agreement Revenue Procedure (31 August 2015)

Transfer Pricing Alert - 2015-012

U.S. Tax Court's Altera Decision Raises Broader Questions (19 August 2015)

Transfer Pricing Alert - 2015-011

U.S. Tax Court Invalidates Cost Sharing Rule in Altera Decision (28 July 2015)

Transfer Pricing alert: 2015-010

OECD Provides Update on Transfer Pricing Issues at July Public Consultation (14 July 2015)

Transfer Pricing alert: 2015-009

OECD Issues Discussion Draft on Hard-to-Value Intangibles (8 June 2015)

Transfer Pricing alert: 2015-008

OECD Releases Draft Guidance on Cost Contribution Arrangements (6 May 2015)

Transfer Pricing alert: 2015-007

2014 U.S. Competent Authority Statistics Reveal Significant Increase in Demand and Inventory, More Expected to Come in 2015 (4 May 2015)

Transfer Pricing alert: 2015-006

2014 U.S. APA Report Shows Program Holding Steady (10 April 2015)

Transfer Pricing alert: 2015-005

Progress on Competent Authority Cases Results in IRS Acceptance of APA Prefiling Conferences for Bilateral U.S.- India APAs (12 March 2015)

Transfer Pricing alert: 2015-004

OECD Issues Guidance on CbC Reporting Implementation (6 February 2015)

Transfer Pricing alert: 2015-003

Singapore Releases New Transfer Pricing Guidelines (2 February 2015)

Transfer Pricing alert: 2015-002

France Increases Penalties for Lack of Compliance With Docmunentation Rules (2 February 2015)

Transfer Pricing alert: 2015-001

India, United States Reach Agreement to Solve Backlog of Competent Authority Cases (21 January 2015)

Transfer Pricing alert: 2014-025

OECD Releases Five Transfer Pricing Discussion Drafts (22 December 2014)

Transfer Pricing alert: 2014-024

Australia Issues Final Guidance on ATO's Controversial Transfer Pricing Reconstruction Power (15 November 2014)

Transfer Pricing alert: 2014-023

OECD Issues Discussion Draft on Low-Value-Adding Intragroup Services (14 November 2014)

Transfer Pricing alert: 2014-022

Greece Issues Templates and Guidelines for APA Negotiations (3 November 2014)

Transfer Pricing alert: 2014-021

Multistate Tax Commission Hears From Firms on Transfer Pricing Project (3 November 2014)

Transfer Pricing alert: 2014-019

BEPS Action Plan Item 13: The New Documentation Standard Implications for the Financial Services Industry (9 October 2014)

Transfer Pricing alert: 2014-018

Singapore Releases Proposed New Transfer Pricing Documentation Guidelines (9 October 2014)

Transfer Pricing alert: 2014-017

France Publishes New Transfer Pricing Documentation Form (22 September 2014)

Transfer Pricing alert: 2014-016

OECD Release on Intangibles: Many Issues Unanswered (19 September 2014)

Transfer Pricing alert: 2014-015

OECD Chapter I Release: Important Guidance on Location-Specific Advantages and Passive Association (18 September 2014)

Transfer Pricing alert: 2014-014

OECD Release on Transfer Pricing Documentation: The New Global Standard (17 September 2014)

Transfer Pricing alert: 2014-013

France Postpones Due Date of New Transfer Pricing Documentation (24 July 2014)

Transfer Pricing alert: 2014-012

India's 2014 Budget Includes Transfer Pricing Proposals (10 July 2014)

Transfer Pricing alert: 2014-011

OECD BEPS Transfer Pricing Deliverables on Track for September G20 Review and Approval (11 June 2014)

Transfer Pricing alert: 2014-010

Mexico’s Supreme Court Rules on Expense Sharing Agreements with Nonresidents (7 May 2014)

Transfer Pricing alert: 2014-009

Greece Provides Guidance on Transfer Pricing Rules (25 April 2014)

Transfer Pricing alert: 2014-008

Italy Clarifies, Amends Transfer Pricing Rules (14 April 2014)

Transfer Pricing alert: 2014-007

Iceland Introduces New Transfer Pricing Rules (14 April 2014)

Transfer Pricing alert: 2014-006

Indian APA Program Takes Off (7 April 2014)

Transfer Pricing alert: 2014-005

2013 U.S. APA Report Shows Significant Efficiency Gains (7 April 2014)

Transfer Pricing alert: 2014-004

OECD Updates Transfer Pricing Documentation Proposal (4 April 2014)

Transfer Pricing alert: 2014-003

IRS Issues Transfer Pricing Audit Roadmap (25 March 2014)

Transfer Pricing alert: 2014-002

Danish Tribunal Rules on Cash Pooling Arrangement (5 March 2014)

Transfer Pricing alert: 2014-001

France Enacts Additional Documentation Requirements (27 January 2014)

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Todd Wolosoff

Global Managing Director – Transfer Pricing, DTTL

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