Transfer pricing alerts

Recent alerts

Transfer Pricing Alert - 2018-004

IRS substantially increases advance pricing agreement user fees (8 February 2018)

Transfer Pricing Alert - 2018-003

Australian tax authorities issue final compliance approach for cross-border related-party debt funding (12 January 2018)

Transfer Pricing Alert - 2018-002

Brazil's CbC reporting requirements for exchange relationships activated after 2017 (12 January 2018)

Transfer Pricing Alert - 2018-001

OECD updates Model Tax Convention (11 January 2018)

Transfer Pricing Alert - 2017-056

Cambodia introduces transfer pricing rules (15 December 2017)

Transfer Pricing Alert - 2017-055

Cyprus extends country-by-country reporting deadlines (14 December 2017)

Transfer Pricing Alert - 2017-054

Italian tax authorities publish guidance on implementation of CbC reporting rules, delay filing due date (14 December 2017)

Transfer Pricing Alert - 2017-053

Greek tax authorities clarify procedures for filing, exchange of CbC reports and submission of CbC report notifications (12 December 2017)

Transfer Pricing Alert - 2017-052

Portugal publishes CbC notification form (12 December 2017)

Transfer Pricing Alert - 2017-051

UK country-by-country reporting filing and notification deadline approaches (11 December 2017)

Transfer Pricing Alert - 2017-050

Belgium extends deadline to file CbC report, master file (7 December 2017)

Transfer Pricing Alert - 2017-049

France provides CbC reporting respite to French subsidiaries of American multinational groups (7 December 2017)

Transfer Pricing Alert - 2017-048

Ireland extends deadline for filing first country-by-country reports (28 November 2017)

Transfer Pricing Alert - 2017-047

IRS issues two advance pricing agreement International Practice Units (14 November 2017)

Transfer Pricing Alert - 2017-046

Portugal delays deadline for filing CbCR notification (27 October 2017)

Transfer Pricing Alert - 2017-045

Transfer Pricing: Deadlines to Preserve Taxpayer Rights to Request Competent Authority Assistance to Relieve Double Taxation (18 October 2017)

Transfer Pricing Alert - 2017-044

OECD Forum on Tax Administration issues handbooks to address implementation and use of CbC reports (18 October 2017)

Transfer Pricing Alert - 2017-043

IRS files notice of appeal in Amazon case (11 October 2017)

Transfer Pricing Alert - 2017-042

Argentina issues country-by-country reporting rules (9 October 2017)

Archive

Transfer Pricing Alert - 2017-041

IRS APMA Program issues draft APA template for comment (27 September 2017)

Transfer Pricing Alert - 2017-040

Malaysia issues sample notification letters for country-by-country reporting (25 September 2017)

Transfer Pricing Alert - 2017-039

Irish report on corporation tax code includes transfer pricing recommendations (22 September 2017)

Transfer Pricing Alert - 2017-038

OECD releases additional implementation guidance on CbC reporting and appropriate use of information in CbC reports (14 September 2017)

Transfer Pricing Alert - 2017-037

Dutch tax authorities set up website for CbC report, notification filings (30 August 2017)

Transfer Pricing Alert - 2017-036

Belgium's country-by-country reporting notification deadline approaches (18 August 2017)

Transfer Pricing Alert - 2017-035

Taiwan to amend transfer pricing rules to adopt Action 13 concepts (11 August 2017)

Transfer Pricing Alert - 2017-034

Malaysia introduces master file requirement, other BEPS recommendations (11 August 2017)

Transfer Pricing Alert - 2017-033

UK country-by-country reporting notification deadline approaches (3 August 2017)

Transfer Pricing Alert - 2017-032

France publishes list of partner countries for automatic exchange of CbC information (3 August 2017)

Transfer Pricing Alert - 2017-031

IRS's determination to cancel Eaton's APAs was abuse of discretion (3 August 2017)

Transfer Pricing Alert - 2017-030

OECD releases additional implementation guidance on CbC reporting (20 July 2017)

Transfer Pricing Alert - 2017-029

IRS launches country-by-country reporting web pages (19 July 2017)

Transfer Pricing Alert - 2017-028

OECD releases new edition of transfer pricing guidelines (12 July 2017)

Transfer Pricing Alert - 2017-027

OECD releases new discussion draft on attribution of profits to PEs (26 June 2017)

Transfer Pricing Alert - 2017-026

OECD releases third discussion draft on transactional profit splits (23 June 2017)

Transfer Pricing Alert - 2017-025

IRS enters into initial country-by-country reporting exchange agreements (30 May 2017)

Transfer Pricing Alert - 2017-024

Portugal extends deadline for filing CbC notification (30 May 2017)

Transfer Pricing Alert - 2017-023

Brazil issues additional guidance on CbC reporting rules (29 May 2017)

Transfer Pricing Alert - 2017-022

ECOFIN agrees on new directive on tax dispute resolution mechanisms (26 May 2017)

Transfer Pricing Alert - 2017-021

Spain publishes draft order approving new form for reporting related-party and tax haven transactions (25 May 2017)

Transfer Pricing Alert - 2017-020

Portugal's CbC notification deadline approaches (24 May 2017)

Transfer Pricing Alert - 2017-019

John Hughes appointed permanent director of IRS's Advance Pricing and Mutual Agreement Program Global Transfer (22 May 2017)

Transfer Pricing Alert - 2017-018

Australia issues draft risk-assessment framework for related-party financing (17 May 2017)

Transfer Pricing Alert - 2017-017

Mexico publishes final master file, local file, and CbC report rules (12 May 2017)

Transfer Pricing Alert - 2017-016

OECD updates guidance on local filing requirements of country-bycountry reports (5 May 2017)

Transfer Pricing Alert - 2017-015

IRS files notice of appeal in Medtronic case (2 May 2017)

Transfer Pricing Alert - 2017-014

Australia’s new penalty laws for CbC reporting and an update on its implementation approach (20 April 2017)

Transfer Pricing Alert - 2017-013

Status of US-Brazil bilateral Competent Authority agreement on automatic exchange of country-by-country report (19 April 2017)

Transfer Pricing Alert - 2017-012

China's SAT issues new rules to improve administration of special tax investigations and Mutual Agreement Procedures (6 April 2017)

Transfer Pricing Alert - 2017-011

2016 US APA Report shows strong interest in agreements with India, Italy (4 April 2017)

Transfer Pricing Alert - 2017-010

Danish courts rule on penalties for missing transfer pricing documentation (3 April 2017)

Transfer Pricing Alert - 2017-009

UK amends country-by-country reporting rules (3 April 2017)

Transfer Pricing Alert - 2017-008

US Tax Court sides with Amazon in intangibles transfer case (27 March 2017)

Transfer Pricing Alert - 2017-007

IRS issues draft instructions for Form 8975 (24 March 2017)

Transfer Pricing Alert - 2017-006

Italy issues rules for implementation of country-by-country reporting (22 March 2017)

Transfer Pricing Alert - 2017-005

Transfer Pricing Implications of New US Tax Return Due Dates for C Corporations (21 March 2017)

Transfer Pricing Alert - 2017-004

New Zealand issues BEPS consultation papers (10 March 2017)

Transfer Pricing Alert - 2017-003

Germany publishes new draft legislation on transfer pricing documentation (6 March 2017)

Transfer Pricing Alert - 2017-002

IRS Releases Initial List of LB&I Campaigns (15 February 2017)

Transfer Pricing Alert - 2017-001

IRS releases guidance on voluntary filing of CbC report for early reporting periods (27 January 2017)