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

August 2018

  • OECD releases discussion draft on transfer pricing of financial transactions
  • India’s CBDT releases guidance on appropriate use of country-by-country reports
  • Ninth Circuit Court of Appeals reverses Tax Court in Altera, then withdraws opinion
  • OECD releases new guidance on transactional profit split method and hard-to-value intangibles
  • France publishes decree on new transfer pricing documentation requirements
  • Hong Kong passes BEPS and transfer pricing laws
  • Germany publishes new guidance on cost sharing arrangements
  • IRS issues Transfer Pricing Examination Process to replace Transfer Pricing Roadmap
  • Norway’s tax authorities issue annual transfer pricing report, and auditor general reports on authorities’ approach to transfer pricing
  • Italy issues new measures on implementation of domestic transfer pricing provisions
August 2018


June 2018
OECD releases additional guidance on attribution of profits to permanent establishments

April 2018
Japan releases revised transfer pricing administrative guidelines

February 2018
Hong Kong to introduce statutory transfer pricing regime

December 2017
India releases final rules on country-by-country reporting and master file

October 2017
OECD releases additional implementation guidance on CbC reporting and appropriate use of information in CbC reports

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