Transfer pricing alerts

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Transfer pricing alerts

Updates on transfer pricing developments around the world.

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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.
 

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Recent alerts

Transfer Pricing Alert - 2019-019

Ninth Circuit Court of Appeals reverses Tax Court in Altera (26 June 2019)

Transfer Pricing Alert - 2019-018

OECD releases program to develop consensus solution to tax challenges arising from digital economy (4 June 2019)

Transfer Pricing Alert - 2019-017

Belgium amends CbC report notification requirement (17 May 2019)

Transfer Pricing Alert - 2019-016

IRS introduces campaign aimed at captive service providers (6 May 2019)

Transfer Pricing Alert - 2019-015

Canada's 2019 budget introduces transfer pricing measures (18 April 2019)

Transfer Pricing Alert - 2019-014

Microsoft wins Danish Supreme Court case (4 April 2019)

Transfer Pricing Alert - 2019-013

2018 US APA Report shows significant continued interest in APAs (4 April 2019)

Transfer Pricing Alert - 2019-012

Uruguay extends due date for filing CbC report (29 March 2019)

Transfer Pricing Alert - 2019-011

India, United States sign agreement to exchange country-by-country reports (29 March 2019)

Transfer Pricing Alert - 2019-010

Belgium tax authorities publish guidance on application of transfer pricing documentation penalty regime (28 March 2019)

Transfer Pricing Alert - 2019-009

Swedish tax authority announces position on relationship between transfer pricing documentation and tax penalties (15 March 2019)

Transfer Pricing Alert - 2019-008

Peru again extends due date for filing CbC report (15 March 2019)

Transfer Pricing Alert - 2019-007

IRS APMA Program releases Functional Cost Diagnostic Model to evaluate potential reliability of profit splits (6 March 2019)

Transfer Pricing Alert - 2019-006

IRS issues memorandum on mandatory consultations between LB&I Exam and APMA Program (4 March 2019)

Archive

Transfer Pricing Alert - 2019-012

Uruguay extends due date for filing CbC report (29 March 2019)

Transfer Pricing Alert - 2019-011

India, United States sign agreement to exchange country-by-country reports (29 March 2019)

Transfer Pricing Alert - 2019-010

Belgium tax authorities publish guidance on application of transfer pricing documentation penalty regime (28 March 2019)

Transfer Pricing Alert - 2019-009

Swedish tax authority announces position on relationship between transfer pricing documentation and tax penalties (15 March 2019)

Transfer Pricing Alert - 2019-008

Peru again extends due date for filing CbC report (15 March 2019)

Transfer Pricing Alert - 2019-007

IRS APMA Program releases Functional Cost Diagnostic Model to evaluate potential reliability of profit splits (6 March 2019)

Transfer Pricing Alert - 2019-006

IRS issues memorandum on mandatory consultations between LB&I Exam and APMA Program (4 March 2019)

Transfer Pricing Alert - 2019-005

Ireland launches public consultation on updating domestic transfer pricing regime (28 February 2019)

Transfer Pricing Alert - 2019-004

OECD releases public consultation document on digital economy (21 February 2019)

Transfer Pricing Alert - 2019-003

Hong Kong's revised profits tax return requires transfer pricing disclosures (18 February 2019)

Transfer Pricing Alert - 2019-002

Germany issues new administrative guidance on deviations from arm's length principle in specific restructuring situations (22 January 2019)

Transfer Pricing Alert - 2019-001

Uruguay issues resolution on CbC reporting requirements (11 January 2019)

Transfer Pricing Alert - 2018-36

Australia issues draft guidelines on inbound distribution arrangements (7 December 2018)

Transfer Pricing Alert - 2018-35

Bulgaria proposes first-ever mandatory transfer pricing documentation requirements (27 November 2018)

Transfer Pricing Alert - 2018-34

Belgium tax authorities acknowledge OECD TP guidelines and share country-specific interpretation in draft transfer pricing circular (16 November 2018)

Transfer Pricing Alert - 2018-33

Peru extends due date for filing CbC report for FY 2017 (13 November 2018)

Transfer Pricing Alert - 2018-32

Egypt releases updated transfer pricing guidelines (12 November 2018)

Transfer Pricing Alert - 2018-31

Australia issues guidance on transfer pricing and financing arrangements (12 November 2018)

Transfer Pricing Alert - 2018-30

Deadlines to preserve taxpayer rights to request Competent Authority assistance to relieve double taxation (7 November 2018)

Transfer Pricing Alert - 2018-29

OECD's newly released MAP statistics reveal number of cases continues to rise (26 October 2018)

Transfer Pricing Alert - 2018-28

Danish court rejects tax authority's proposed adjustment in MNE group restructuring (17 October 2018)

Transfer Pricing Alert - 2018-27

Irish government publishes corporate tax regime roadmap (27 September 2018)

Transfer Pricing Alert - 2018-26

OECD releases additional implementation guidance on CbC reporting (24 September 2018)

Transfer Pricing Alert - 2018-25

Mexico substantially modifies transfer pricing adjustment rules (13 September 2018)

Transfer Pricing Alert - 2018-24

New Zealand releases BEPS guidance to provide clarity (7 September 2018)

Transfer Pricing Alert - 2018-23

France publishes decree on new transfer pricing documentation requirements (7 August 2018)

Transfer Pricing Alert - 2018-22

IRS issues Transfer Pricing Examination Process to replace Transfer Pricing Roadmap (7 August 2018)

Transfer Pricing Alert - 2018-21

OECD releases discussion draft on transfer pricing of financial transactions (26 July 2018)

Transfer Pricing Alert - 2018-20

OECD releases new guidance on transactional profit split method and hard-to-value intangibles (17 July 2018)

Transfer Pricing Alert - 2018-019

Germany publishes new guidance on cost sharing arrangements (17 July 2018)

IRS issues new APA template (13 June 2018)

Transfer Pricing Alert - 2018-017

Irish Revenue release details on monitoring compliance with transfer pricing rules (7 June 2018)

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