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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Recent newsletters appear below; for older issues, please email a request to

October 2017

  • OECD releases additional implementation guidance on CbC reporting and appropriate use of information in CbC reports
  • Argentina issues rules on exchange of country-by-country information
  • Taiwan to amend transfer pricing rules to adopt Action 13 concepts
  • Irish report on corporation tax code includes transfer pricing recommendations
  • Malaysia issues sample notification letters for country-by-country reporting
  • IRS APMA Program issues draft APA template for comment
  • Kosovo issues guidance on transfer pricing procedures and documentation requirements
  • Deadline for French SMEs to file transfer pricing form approaching
  • Italy’s postponement of tax return filing deadline affects both transfer pricing documentation and CbC notification.


August 2017
OECD releases new edition of transfer pricing guidelines

June 2017
Australia’s new penalty laws for CbC reporting and an update on its implementation approach

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

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