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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June 2017

  • Australia’s new penalty laws for CbC reporting and an update on its implementation approach
  • IRS files notice of appeal in Medtronic case
  • OECD updates guidance on local filing requirements of country-by-country reports
  • Mexico publishes final master file, local file, and CbC report rules
  • Australia issues draft risk-assessment framework for related-party financing
  • Global Tax Reset: Transfer Pricing Documentation Summary
  • Portugal extends deadline for filing CbC notification
  • Spain publishes draft order approving new form for reporting related-party and tax haven transactions
  • ECOFIN agrees on new directive on tax dispute resolution mechanisms
  • Reflections on the Chevron debt financing transfer pricing case – a post-BEPS decision?
  • IRS enters into initial country-by-country reporting exchange agreements
  • Brazil issues additional guidance on CbC reporting rules
  • OECD releases additional guidance on CbC reporting
  • John Hughes appointed permanent director of IRS’s Advance Pricing and Mutual Agreement Program
June 2017


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

August 2016
China’s SAT issues new rules on reporting of related-party transactions and contemporaneous documentation

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