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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April 2019

  • IRS issues memorandum on mandatory consultations between LB&I Exam and APMA Program
  • Peru again extends due date for filing CbC report
  • India, United States sign agreement to exchange country-by-country reports
  • Swedish tax authority announces position on relationship between transfer pricing documentation and tax penalties
  • IRS APMA Program releases Functional Cost Diagnostic Model to evaluate potential reliability of profit splits
  • Belgium tax authorities publish guidance on application of transfer pricing documentation penalty regime
  • Uruguay extends due date for filing CbC report
  • 2018 US APA Report shows significant continued interest in APAs
  • Saudi Arabia issues final transfer pricing regulations
  • India’s ITAT accepts industry average rate as CUP for royalty payments
April 2019


February 2019
Saudi Arabia releases draft transfer pricing regulations

December 2018
Australia issues guidance on transfer pricing and financing arrangements

October 2018
New Zealand releases BEPS guidance to provide clarity

August 2018
OECD releases discussion draft on transfer pricing of financial transactions

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

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