Arm's Length Standard

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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 globaltaxpublications@deloitte.com.

October 2019

  • OECD proposes “unified approach” to Pillar 1 of project to address tax challenges from digitalization of the economy
  • Australian Federal Court agrees with taxpayer in court challenge to transfer pricing adjustments
  • US Court of Appeals affirms Tax Court decision in Amazon
  • OECD’s newly released 2018 MAP statistics indicate total number of cases continues to increase
  • Denmark will allow reopening of old tax years following transfer pricing ruling
  • Ireland’s Department of Finance issues draft transfer pricing legislation
  • Panama establishes regulatory framework for country-by-country report
  • Saudi Arabia starts requesting transfer pricing documentation
  • Denmark proposed legislation would amend transfer pricing rules
  • Australia issues guidance on nonresident-owned mobile offshore drilling units in Australian waters
  • Financial services transfer pricing: Bringing the tax dimension of banking reforms into focus
  • Bulgaria introduces mandatory transfer pricing documentation rules
  • Israel updates transfer pricing declaration form, but taxpayers may opt not to use it for 2018 reporting
October 2019

Archive

August 2019
Ninth Circuit Court of Appeals reverses Tax Court in Altera

June 2019
OECD releases program to develop consensus solution to tax challenges arising from digital economy

April 2019
IRS issues memorandum on mandatory consultations between LB&I Exam and APMA Program

February 2019
Saudi Arabia releases draft transfer pricing regulations

December 2018
Australia issues guidance on transfer pricing and financing arrangements

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