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Transfer pricing alerts
Updates on transfer pricing developments around the world.
Recent alerts and an archive of alerts from the previous 12 months appear below; for older issues, please email a request to globaltaxpublications@deloitte.com.
Recent alerts
Transfer Pricing Alert - 2019-031
ATO issues guidance on nonresident-owned mobile offshore drilling units in Australian waters (27 September 2019)
Transfer Pricing Alert - 2019-030
OECD's newly released 2018 MAP statistics indicate that total number of cases continues to increase (27 September 2019)
Transfer Pricing Alert - 2019-029
Denmark proposed legislation would amend transfer pricing rules (24 September 2019)
Transfer Pricing Alert - 2019-028
Saudi Arabia starts requesting transfer pricing documentation (13 September 2019)
Transfer Pricing Alert - 2019-027
Bulgaria introduces mandatory transfer pricing documentation rules (12 September 2019)
Transfer Pricing Alert - 2019-026
Panama establishes regulatory framework for country-by-country report (12 September 2019)
Transfer Pricing Alert - 2019-025
Ireland's Department of Finance issues draft transfer pricing legislation (6 September 2019)
Transfer Pricing Alert - 2019-024
US Court of Appeals affirms Tax Court decision in Amazon (22 August 2019)
Transfer Pricing Alert - 2019-023
Denmark will allow reopening of old tax years following transfer pricing ruling (21 August 2019)
Transfer Pricing Alert - 2019-022
Botswana introduces transfer pricing regulations (8 August 2019)
Transfer Pricing Alert - 2019-021
IRS to resume examining stock-based compensation issues (7 August 2019)
Transfer Pricing Alert - 2019-020
Argentina extends transfer pricing due dates (31 July 2019)
Archive
Transfer Pricing Alert - 2019-019
Ninth Circuit Court of Appeals reverses Tax Court in Altera (26 June 2019)
Transfer Pricing Alert - 2019-018
OECD releases program to develop consensus solution to tax challenges arising from digital economy (4 June 2019)
Transfer Pricing Alert - 2019-017
Belgium amends CbC report notification requirement (17 May 2019)
Transfer Pricing Alert - 2019-016
IRS introduces campaign aimed at captive service providers (6 May 2019)
Transfer Pricing Alert - 2019-015
Canada's 2019 budget introduces transfer pricing measures (18 April 2019)
Transfer Pricing Alert - 2019-014
Microsoft wins Danish Supreme Court case (4 April 2019)
Transfer Pricing Alert - 2019-013
2018 US APA Report shows significant continued interest in APAs (4 April 2019)
Transfer Pricing Alert - 2019-012
Uruguay extends due date for filing CbC report (29 March 2019)
Transfer Pricing Alert - 2019-011
India, United States sign agreement to exchange country-by-country reports (29 March 2019)
Transfer Pricing Alert - 2019-010
Belgium tax authorities publish guidance on application of transfer pricing documentation penalty regime (28 March 2019)
Transfer Pricing Alert - 2019-009
Swedish tax authority announces position on relationship between transfer pricing documentation and tax penalties (15 March 2019)
Transfer Pricing Alert - 2019-008
Peru again extends due date for filing CbC report (15 March 2019)
Transfer Pricing Alert - 2019-007
IRS APMA Program releases Functional Cost Diagnostic Model to evaluate potential reliability of profit splits (6 March 2019)
Transfer Pricing Alert - 2019-006
IRS issues memorandum on mandatory consultations between LB&I Exam and APMA Program (4 March 2019)
Transfer Pricing Alert - 2019-005
Ireland launches public consultation on updating domestic transfer pricing regime (28 February 2019)
Transfer Pricing Alert - 2019-004
OECD releases public consultation document on digital economy (21 February 2019)
Transfer Pricing Alert - 2019-003
Hong Kong's revised profits tax return requires transfer pricing disclosures (18 February 2019)
Transfer Pricing Alert - 2019-002
Germany issues new administrative guidance on deviations from arm's length principle in specific restructuring situations (22 January 2019)
Transfer Pricing Alert - 2019-001
Uruguay issues resolution on CbC reporting requirements (11 January 2019)
Transfer Pricing Alert - 2018-36
Australia issues draft guidelines on inbound distribution arrangements (7 December 2018)
Transfer Pricing Alert - 2018-35
Bulgaria proposes first-ever mandatory transfer pricing documentation requirements (27 November 2018)
Transfer Pricing Alert - 2018-34
Belgium tax authorities acknowledge OECD TP guidelines and share country-specific interpretation in draft transfer pricing circular (16 November 2018)
Transfer Pricing Alert - 2018-33
Peru extends due date for filing CbC report for FY 2017 (13 November 2018)
Transfer Pricing Alert - 2018-32
Egypt releases updated transfer pricing guidelines (12 November 2018)
Transfer Pricing Alert - 2018-31
Australia issues guidance on transfer pricing and financing arrangements (12 November 2018)
Transfer Pricing Alert - 2018-30
Deadlines to preserve taxpayer rights to request Competent Authority assistance to relieve double taxation (7 November 2018)
Transfer Pricing Alert - 2018-29
OECD's newly released MAP statistics reveal number of cases continues to rise (26 October 2018)
Transfer Pricing Alert - 2018-28
Danish court rejects tax authority's proposed adjustment in MNE group restructuring (17 October 2018)
IRS issues new APA template (13 June 2018)
Transfer Pricing Alert - 2018-017
Irish Revenue release details on monitoring compliance with transfer pricing rules (7 June 2018)