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 2017

  • OECD releases new edition of transfer pricing guidelines
  • IRS’s determination to cancel Eaton’s APAs was abuse of discretion
  • UK country-by-country reporting notification deadline approaches
  • Singapore proposes mandatory transfer pricing documentation requirement and penalties
  • Greece implements country-by-country reporting requirement
  • OECD releases third discussion draft on transactional profit splits
  • OECD releases new discussion draft on attribution of profits to PEs
  • Kazakhstan releases draft legislation on country-by-country reporting requirements
  • Israeli government wins transfer pricing case on sale of IP
  • Malaysia introduces master file requirement, other BEPS recommendations
  • IRS launches country-by-country reporting web pages
  • OECD releases additional implementation guidance on CbC reporting
  • France publishes list of partner countries for automatic exchange of CbC information
August 2017


June 2017
Australia’s new penalty laws for CbC reporting and an update on its implementation approach

April 2017
US Tax Court sides with Amazon in intangibles transfer case

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

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