Arm's Length Standard


Arm's Length Standard

Global views within reach.

Arm's Length Standard is a bulletin of transfer pricing developments written by professionals of the member firms of Deloitte. The newsletter covers transfer pricing developments worldwide.

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Recent newsletters appear below; for older issues, please email a request to

April 2017

  • US Tax Court sides with Amazon in intangibles transfer case
  • China’s SAT issues new rules to improve administration of Special Tax Investigation and Adjustment and Mutual Agreement Procedures
  • UK amends country-by-country reporting rules
  • IRS Releases Initial List of LB&I Campaigns
  • Germany publishes new draft legislation on transfer pricing documentation
  • New Zealand issues BEPS consultation papers
  • Danish courts rule on penalties for missing transfer pricing documentation
  • 2016 US APA Report shows strong interest in agreements with India, Italy
  • Canada’s country-by-country legislation comes into force, CRA releases Form RC4649
  • Transfer Pricing Implications of New US Tax Return Due Dates for C Corporations
  • Italy issues rules for implementation of country-by-country reporting
  • IRS issues draft instructions for Form 8975
April 2017


February 2017
IRS issues final section 367(a) and (d) regulations

December 2016
OECD issues additional guidance on CbC reporting

October 2016
Denmark issues final statutory order on country-by-country reporting

August 2016
China’s SAT issues new rules on reporting of related-party transactions and contemporaneous documentation

June 2016
Germany’s draft tax law includes CbC measures

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