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October 2019

• OECD proposes “unified approach” to Pillar 1 of project to address tax challenges from digitalization of the economy
• Australian Federal Court agrees with taxpayer in court challenge to transfer pricing adjustments
• US Court of Appeals affirms Tax Court decision in Amazon
• OECD’s newly released 2018 MAP statistics indicate total number of cases continues to increase
• Denmark will allow reopening of old tax years following transfer pricing ruling
• Ireland’s Department of Finance issues draft transfer pricing legislation
• Panama establishes regulatory framework for country-by-country report
• Saudi Arabia starts requesting transfer pricing documentation
• Denmark proposed legislation would amend transfer pricing rules
• Australia issues guidance on nonresident-owned mobile offshore drilling units in Australian waters
• Financial services transfer pricing: Bringing the tax dimension of banking reforms into focus
• Bulgaria introduces mandatory transfer pricing documentation rules
• Israel updates transfer pricing declaration form, but taxpayers may opt not to use it for 2018 reporting