Transfer pricing alerts

Recent alerts

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)

Archive

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)

Transfer Pricing Alert - 2016-040

IRS issues final section 367(a) and (d) regulations (21 December 2016)

Transfer Pricing Alert - 2016-039

Irish tax authorities update guidance on CbC reporting (20 December 2016)

Transfer Pricing Alert - 2016-038

OECD issues additional guidance on CbC reporting (6 December 2016)

Transfer Pricing Alert - 2016-037

Performance audit of IRS concludes transfer pricing issues not being properly evaluated (10 November 2016)

Transfer Pricing Alert - 2016-036

OECD issues guidance on Action 14 peer reviews (2 November 2016)

Transfer Pricing Alert - 2016-035

Transfer Pricing: Deadlines to Preserve Taxpayer Rights to Request Competent Authority Assistance to Relieve Double Taxation (1 November 2016)

Transfer Pricing Alert - 2016-034

IRS announces position on unilateral APA applications by maquiladoras (24 October 2016)

Transfer Pricing Alert - 2016-033

Irish Revenue releases updated guidance on country-by-country reporting (19 October 2016)

Transfer Pricing Alert - 2016-032

France publishes decree on country-by-country reporting (7 October 2016)

Transfer Pricing Alert - 2016-031

Denmark issues final statutory order on country-by-country reporting (7 October 2016)

Transfer Pricing Alert - 2016-030

Austria's Transfer Pricing Documentation Act officially published (15 August 2016)

Transfer Pricing Alert - 2016-029

Luxembourg issues draft law on country-by-country reporting (8 August 2016)

Transfer Pricing Alert - 2016-028

Canada releases draft legislation on country-by-country reporting (5 August 2016)

Transfer Pricing Alert - 2016-027

Belgium finalizes mandatory transfer pricing reporting requirements (4 August 2016)

Transfer Pricing Alert - 2016-026

China's SAT issues new rules on reporting of related-party transactions and contemporaneous documentation (14 July 2016)

Transfer Pricing Alert - 2016-025

OECD releases discussion draft on revised guidance on profit splits (12 July 2016)

Transfer Pricing Alert - 2016-024

United States issues final country-by-country reporting regulations (1 July 2016)

Transfer Pricing Alert - 2016-023

OECD issues additional guidance on CbC reporting (1 July 2016)

Transfer Pricing Alert - 2016-022

Ireland introduces bilateral APA program (30 June 2016)

Transfer Pricing Alert - 2016-021

OECD approves incorporation of BEPS amendments into transfer pricing guidelines (17 June 2016)

Transfer Pricing Alert - 2016-020

In Medtronic, U.S. Tax Court rules against IRS's use of CPM, applies CUT method (14 June 2016)

Transfer Pricing Alert - 2016-019

Germany's draft tax law includes CbC measures (9 June 2016)

Transfer Pricing Alert - 2016-018

Austria plans introduction of standardized transfer pricing documentation (9 June 2016)