Stiri
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 - 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)
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)