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Recent Articles
January 2024
25 Jan - Colombia: New deadlines for transfer pricing documentation
22 Jan - Australia: Practical compliance guideline on intangibles arrangements
22 Jan - United States: Resurgence of transfer pricing penalties
19 Jan - Bulgaria: Public country-by-country reporting implemented
19 Jan - Czech Republic: Public country-by-country reporting implemented
19 Jan - EU: Challenge to EU global minimum tax directive dismissed (EU General Court judgment)
18 Jan - Italy: Pillar Two global minimum tax rules implemented
17 Jan - EU: Pillar Two global minimum tax implementation summary
17 Jan - Italy: New tax calendar, implications for transfer pricing documentation
16 Jan - Belgium: Lower house of Parliament adopts draft law implementing public country-by-country reporting
16 Jan - UK: Updates on Pillar Two, including draft HMRC guidance on proposed rules
11 Jan - KPMG report: Comments on European Commission consultation on transfer pricing initiative
10 Jan - Korea: Amendments to Pillar Two rules enacted
4 Jan - Qatar: Extended deadline for country-by-country reports and notifications
2 Jan - Hong Kong: Consultation paper on implementation of Pillar Two global minimum tax
2 Jan - KPMG report: Pillar Two rules and the asset management industry
2023 Articles
December 2023
26 Dec - China: Advance pricing arrangement annual report for 2022
22 Dec - EU: EC publishes FAQs on interpretation and transposition of EU global minimum tax
20 Dec - KPMG report: New administrative guidance on Pillar Two rules, initial observations and analysis
20 Dec - EU: Pillar Two global minimum tax implementation summary
20 Dec - Luxembourg: Law implementing Pillar Two global minimum tax enacted
20 Dec - Netherlands: 2024 Tax Plan package and law implementing Pillar Two global minimum tax enacted
20 Dec - Netherlands: Senate approves legislation implementing public country-by-country reporting
19 Dec - Ireland: Legislation implementing Pillar Two signed into law
19 Dec - Hong Kong: Update on implementation of Pillar Two global minimum tax
15 Dec - Belgium: Pillar Two global minimum tax rules adopted by Parliament
15 Dec - KPMG report: Transfer pricing implications of Pillar Two minimum tax rules
14 Dec - Moldova: Public country-by-country reporting implemented
8 Dec - Croatia: Consultation on draft legislation implementing Pillar Two global minimum tax
8 Dec - Hungary: Legislation implementing Pillar Two global minimum tax enacted
8 Dec - Moldova: Draft law implementing country-by-country reporting
8 Dec - UK: Finance Bill 2024, including amendments to Pillar Two minimum tax rules
6 Dec - Luxembourg: Amended draft law implementing Pillar Two global minimum tax
5 Dec - KPMG report: OECD official provides update on expected transfer pricing guidance
1 Dec - KPMG report: IRS large foreign-owned transfer pricing initiative aimed at inbound distributors
November 2023
29 Nov - Vietnam: Resolution adopting Pillar Two global minimum tax
28 Nov - Poland: Extended deadline for submitting certain transfer pricing reporting forms
27 Nov - Greece: Public country-by-country reporting implemented
27 Nov - UK: Update on consultation on proposed changes to transfer pricing and permanent establishment rules
27 Nov - KPMG report: Transfer pricing of financial transactions
24 Nov - KPMG report: Transfer pricing takeaways from 2022 MAP statistics
21 Nov - OECD: Aggregated country-by-country reporting data
21 Nov - KPMG report: Pillar Two implications for “U.S. sandwich structures”
16 Nov - Bermuda: Third public consultation related to proposed corporate income tax
16 Nov - Poland: Extended deadlines for transfer pricing reporting
14 Nov - Germany: Law implementing Pillar Two global minimum tax passed by lower house of Parliament
14 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2022
13 Nov - Barbados: Proposed rules to implement Pillar Two global minimum tax
13 Nov - Brazil: Modification of multiple-year data table under new transfer pricing rules
9 Nov - Cyprus: Consent to Pillar Two global minimum tax rules
9 Nov - Estonia: Legislative proposal implementing Pillar Two global minimum tax rules
9 Nov - Finland: Reservations on proposed EU BEFIT, transfer pricing, and head office tax system directives
9 Nov - Greece: Public consultation on implementation of public country-by-country reporting
9 Nov - Sweden: Reservations on proposed EU transfer pricing directive
October 2023
31 Oct - Poland: Deadline for transfer pricing reporting for 2022 extended
31 Oct - UAE: Transfer pricing guide issued
27 Oct - KPMG report: U.S. transfer pricing and international tax year-end considerations
25 Oct - Australia: Extended due date for filing country-by-country (CbC) reports, Master and Local files
23 Oct - Hungary: Proposed legislation implementing Pillar Two global minimum tax
23 Oct - Korea: Services fee arrangement satisfied arm’s length principle (Tax Tribunal decision)
23 Oct - Romania: Proposed legislation implementing Pillar Two global minimum tax
20 Oct - Ireland: Tax proposals in Finance bill 2023 include implementation of Pillar Two global minimum tax
17 Oct - KPMG report: Mexico’s reference effective tax rates aid voluntary compliance
17 Oct - Poland: New electronic templates for transfer pricing reporting
17 Oct - Belgium: Public country-by-country reporting draft law approved
11 Oct - Poland: Guidance on transfer pricing cost-plus method
6 Oct - Bermuda: Second public consultation related to proposed corporate income tax
6 Oct - Cyprus: Public consultation on draft legislation implementing Pillar Two global minimum tax
5 Oct - Bulgaria: Public consultation on draft legislation implementing Pillar Two global minimum tax
5 Oct - France: Draft legislation implementing Pillar Two global minimum tax
5 Oct - Latvia: Public country-by-country reporting legislation approved
5 Oct - Austria: Draft legislation implementing Pillar Two global minimum tax
4 Oct - Brazil: New transfer pricing rules published
3 Oct - OECD: Multilateral convention to facilitate implementation of Pillar Two subject to tax rule
September 2023
29 Sep - Slovakia: Draft legislation implementing Pillar Two global minimum tax
29 Sep - UK: Updated Finance Bill 2023 draft legislation, including Pillar Two global minimum tax rules
26 Sep - Poland: Amendments to decrees on transfer pricing reporting now effective
20 Sep - OECD: Comments on public consultation document on Amount B under Pillar One
20 Sep - Kenya: Public consultation on draft transfer pricing rules
18 Sep - Italy: Draft law implementing Pillar Two global minimum tax
18 Sep - Sweden: Draft law implementing Pillar Two global minimum tax
15 Sep - Netherlands: Memorandum to parliament in response to report regarding bill implementing Pillar Two
12 Sep - KPMG report: Estimating an arm’s length range for North American retailers
5 Sep - Greece: Updated procedure for advance pricing agreements
August 2023
30 Aug - Portugal: Public country-by-country reporting legislation approved
29 Aug - Finland: Public consultation on implementation of Pillar Two global minimum tax rules
29 Aug - Netherlands: Draft legislation implementing public country-by-country reporting
25 Aug - KPMG report: Potential U.S. tax implications of proposed Bermuda corporate income tax
23 Aug - Israel: Guidance on competent authority, mutual agreement, and bilateral APA procedures
21 Aug - Korea: Proposed amendments to transfer pricing and Pillar Two rules
15 Aug - Australia: Targeted consultation on implementation of Pillar Two global minimum tax rules
14 Aug - Canada: Draft legislation includes Pillar Two rules and revised DST and EIFEL rules
10 Aug - Korea: Tax reform proposal for 2023, changes to Pillar Two and transfer pricing documentation rules
10 Aug - Luxembourg: Draft law implementing Pillar Two global minimum tax
9 Aug - Bermuda: Implementation of corporate income tax within scope of Pillar Two global minimum tax rules
7 Aug - Australia: Audit on ATO’s management of transfer pricing for related-party debt
4 Aug - Belgium: Overview of APA system
4 Aug - Croatia: Implementation of public country-by-country reporting
4 Aug - EU: Formal notice to 14 member states of failure to implement public country-by-country reporting
4 Aug - Ireland: Feedback statement on implementation of Pillar Two global minimum tax
July 2023
31 Jul - EU: Public country-by-country reporting implementation summary
25 Jul - KPMG report: OECD’s effort to simplify transfer pricing
25 Jul - KPMG report: New guidance on Pillar Two rules, initial observations and analysis
25 Jul - KPMG report: Public consultation on Amount B under Pillar One, initial observations
24 Jul - UK: Transfer pricing records regulations published
19 Jul - KPMG report: Transfer pricing and stock-based compensation
17 Jul - OECD: Report on BEPS 2.0, including new guidance on Pillar Two rules
13 Jul - France: New transfer pricing measures announced for 2024 Draft Finance Bill
13 Jul - Thailand: Guidance for taxpayers within scope of Pillar Two global minimum tax rules
12 Jul - EU: European Commission progress report on Pillar One
12 Jul - Germany: Draft bill implementing Pillar Two global minimum tax
12 Jul - Liechtenstein: Consultation on implementation of public country-by-country reporting
12 Jul - Netherlands: Proposed amendments to tax ruling policy
12 Jul - OECD: Outcome statement on BEPS 2.0
7 Jul - Brazil: Public consultation on new transfer pricing rules
6 Jul - Australia: Report on review of advance pricing agreement program
June 2023
29 Jun - Romania: Amendments to public country-by-country reporting rules
28 Jun - France: Implementation of public country-by-country reporting
28 Jun - Lithuania: Country-by-country reporting directive transposed into domestic law
27 Jun - Denmark: Public consultation on draft bill to implement Pillar Two global minimum tax
27 Jun - KPMG report: Europe, Middle East, and Africa (EMA) transfer pricing insights (June 2023)
26 Jun - Australia: Delay in implementation of public country-by-country reporting
26 Jun - KPMG report: Transfer pricing methods for asset management sub-advisers
26 Jun - UK: Consultation on transfer pricing, permanent establishment, and DPT rules
26 Jun - UK: Spring Finance Bill 2023, including Pillar Two global minimum tax rules, substantively enacted
26 Jun - UK: Draft guidance on Pillar Two global minimum tax rules published, comments requested
23 Jun - Chile: Extension of deadline for filing transfer pricing affidavits
22 Jun - Germany: Legislation to implement country-by-country reporting directive
21 Jun - KPMG reports: Transfer pricing considerations in mergers and acquisitions, focus on UK
21 Jun - Switzerland: Implementation of Pillar Two minimum tax approved by public vote
21 Jun - United States: JCT analysis of possible effects of Pillar Two global minimum tax adoption
20 Jun - KPMG report: Transfer pricing considerations for ESG-related intangible assets
16 Jun - Norway: Draft legislation implementing Pillar Two minimum tax
15 Jun - Brazil: OECD-aligned transfer pricing rules signed by president
14 Jun - Denmark: Public country-by-country reporting legislation passed
13 Jun - Kenya: Declaration of related-party or controlled transactions on income tax company returns
12 Jun - Hong Kong: Update on profits tax, BEPS 2.0, and e-filing
12 Jun - Canada: Consultation on proposed transfer pricing rules
8 Jun - Canada: Mutual agreement procedure (MAP) statistics for 2021
8 Jun - Liechtenstein: Consultation draft for implementation of Pillar Two global minimum tax
7 Jun - KPMG report: Transfer pricing implications of automotive innovation
6 Jun - Switzerland: Consultation on draft law implementing Pillar Two global minimum tax
5 Jun - Netherlands: Bill implementing Pillar Two presented to Lower House of Parliament
1 Jun - Malaysia: Transfer pricing and advance pricing arrangement rules 2023
May 2023
30 May - KPMG report: Practical transfer pricing compliance in a complex world
22 May - New Zealand: May 2023 Tax Bill includes Pillar Two global minimum tax rules
19 May - Australia: Updated draft practical compliance guideline on intangibles arrangements
19 May - EU: Action seeking annulment of EU minimum tax directive (EU General Court)
17 May - Switzerland: Transfer pricing topics of focus in audits and ruling requests
16 May - Indonesia: Overview of transfer pricing environment
12 May - UAE: New transfer pricing documentation requirements
11 May - Brazil: OECD-aligned transfer pricing rules passed by Senate
10 May - United States: KPMG analysis of IRS 2022 APA statistics
8 May - Kenya: Transfer pricing, direct, and indirect tax measures in Finance Bill, 2023
8 May - KPMG report: Progress on improving mutual agreement procedure
1 May - United States: IRS guidance on review and acceptance of APA submissions
April 2023
28 Apr - Japan: 2023 tax reform includes income inclusion rule, CFC regime
24 Apr - Korea: Criteria for selection of comparable companies (Tax Tribunal decision)
20 Apr - Lithuania: Draft legislation implementing public country-by-country reporting
17 Apr - Saudi Arabia: Amendments to transfer pricing bylaws
12 Apr - KPMG report: Transfer pricing and ESG—public tax strategies and tax transparency
11 Apr - Australia: Draft legislation for public country-by-country (CbC) reporting
5 Apr - Ireland: Draft legislation on implementation of Pillar Two global minimum tax
4 Apr - Poland: Guidance on resale price method
3 Apr - UK: Implementation of Pillar Two global minimum tax under Spring Finance Bill 2023
March 2023
31 Mar - Brazil: OECD-aligned transfer pricing rules passed by Chamber of Deputies, await vote in Senate
30 Mar - Serbia: Rulebook on arm’s length interest rates for 2023
29 Mar - United States: APMA program, APA statistics for 2022 (IRS Announcement 2023-10)
29 Mar - Vietnam: MAAC signed, intention to implement Pillar Two global minimum tax
27 Mar - KPMG report: Evaluating the equivalence of cost-sharing and cost contribution arrangements
27 Mar - Sweden: Draft legislation implementing public country-by-country reporting presented to parliament
23 Mar - Germany: Public consultation on implementation of Pillar Two global minimum tax
23 Mar - Sweden: Proposed additions to interim report on implementation of EU global minimum tax directive
22 Mar - Spain: Public consultation on Pillar Two global minimum tax
21 Mar - Montenegro: Amendments to tax law include changes to Local file requirements
20 Mar - Korea: Advance customs valuation arrangement, coordination with transfer pricing
16 Mar - OECD: Public consultation meeting on implementation under Pillar Two
15 Mar - Poland: Extended deadline for submitting ORD-U reports
14 Mar - Thailand: Measures to support implementation of Pillar Two global minimum tax rules
10 Mar - Cyprus: Frequently asked questions on transfer pricing documentation rules
10 Mar - Luxembourg: Draft legislation for implementation of public country-by-country reporting
8 Mar - KPMG report: Transfer pricing implications of intercompany fees for internal carbon pricing
7 Mar - Poland: Public consultation on transfer pricing cost-plus method regulations
February 2023
27 Feb - Brazil: Guidance on new OECD-aligned transfer pricing rules
24 Feb - South Africa: Proposed legislative framework for APAs in 2023 budget
16 Feb - OECD: Comments on public consultation documents on implementation under Pillar Two
15 Feb - UK: HMRC transfer pricing and diverted profits tax statistics for year ended 31 March 2022
13 Feb - Sweden: Proposal for implementation of public country-by-country reporting
6 Feb - Qatar: Amendment of transfer pricing-related provisions of Income Tax Law for 2018
3 Feb - KPMG report: Comments on public consultation documents on implementation under Pillar Two
2 Feb - KPMG report: U.S. accounting questions related to new GloBE rules
2 Feb - OECD: Administrative guidance for implementation of Pillar Two global minimum tax rules
January 2023
31 Jan - Estonia: Country-by-country reporting and transfer pricing documentation deadlines
30 Jan - OECD: Comments on public consultation document on Amount B under Pillar One
25 Jan - KPMG report: Comments on public consultation document on Amount B under Pillar One
24 Jan - OECD: Comments on public consultation document on withdrawal of DSTs under Pillar One
23 Jan - Hungary: Changes to transfer pricing rules, including reporting and documentation
20 Jan - KPMG report: Comments on public consultation document on withdrawal of DSTs under Pillar One
20 Jan - KPMG report: Where next for Amount B?
19 Jan - South Africa: Interpretation note providing transfer pricing guidance on intragroup loans
18 Jan - OECD: Revenue gains from BEPS 2.0 predicted to be higher than previously expected
13 Jan - OECD: Manal Corwin appointed new Director of its Centre for Tax Policy and Administration
13 Jan - Slovakia: Changes to content of transfer pricing documentation
12 Jan - Panama: Deadline for submitting 2021 country-by-country reports extended to 15 January 2023
11 Jan - Spain: Public country-by-country reporting implemented
10 Jan - North Macedonia: Proposed changes to transfer pricing reporting
3 Jan - Montenegro: Arm’s length interest rate for 2023
3 Jan - Poland: Interest rates for transfer pricing purposes
2022 Articles
December 2022
29 Dec - Brazil: Draft legislation to align transfer pricing rules with OECD Transfer Pricing Guidelines
22 Dec - Morocco: Temporary suspension of country-by-country report local filing requirement
22 Dec - Belgium: Year-end transfer pricing considerations
22 Dec - Latvia: Penalty for non-compliant transfer pricing documentation
21 Dec - KPMG report: Pillar Two implementation package, initial observations and analysis
20 Dec - UAE: New transfer pricing rules
19 Dec - Serbia: Rulebook on arm’s length interest rates for 2022
19 Dec - KPMG report: Europe, Middle East, and Africa (EMA) transfer pricing insights
16 Dec - Switzerland: Parliament approves constitutional amendment to implement Pillar Two global minimum tax
16 Dec - Korea: Tax authority’s determination of arm’s length price upheld (Tax Tribunal decision)
16 Dec - EU: Council adopts EU minimum tax directive
15 Dec - Hungary: Guidance on transfer pricing reporting
13 Dec - EU: Member states in the EU reach agreement to implement Pillar Two (updated)
13 Dec - United States: Consideration of tax consequences in determining arm’s length result (GLAM)
13 Dec - Czech Republic: Tax loss from transfer pricing adjustments abroad denied (court decision)
13 Dec - Poland: Amendments to decrees on transfer pricing reporting
12 Dec - UAE: Implementation of new federal corporate income tax system, related transfer pricing rules
12 Dec - KPMG report: U.S. administrative law basics for transfer pricing professionals
9 Dec - KPMG report: Public consultation on Amount B under Pillar One, initial observations and analysis
9 Dec - Slovakia: Changes to transfer pricing rules and limitations on deductibility of interest
9 Dec - Slovakia: Public country-by-country reporting implemented
8 Dec - OECD: Public consultation document on Amount B under Pillar One
7 Dec - United States: MAP and the exhaustion of remedies for FTC purposes
6 Dec - KPMG report: OECD official provides update on work on Amount B
6 Dec - EU: Minimum tax directive proposal removed from ECOFIN meeting agenda
6 Dec - Kenya: Country-by-country reporting multilateral competent authority agreement signed
6 Dec - Romania: Public country-by-country reporting implemented
November 2022
30 Nov - Poland: Legislation implementing “public” country-by-country reporting directive announced
30 Nov - KPMG report: Transfer pricing in the soccer field
29 Nov - KPMG report: Key takeaways from the OECD’s 2021 mutual agreement procedure (MAP) statistics
28 Nov - China: Advance pricing arrangement annual report for 2021
28 Nov - Qatar: Transfer pricing documentation requirements
22 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2021
22 Nov - EU: Public country-by-country reporting implementation summary
22 Nov - Malta: Formal transfer pricing rules published
17 Nov - OECD: Aggregated country-by-country reporting data
16 Nov - United States: Year-end tax discussion ideas for international tax and transfer pricing
14 Nov - Montenegro: Guidance under new transfer pricing rules
11 Nov - UK: Implications of interest rate increases for transfer pricing
3 Nov - Hungary: Draft legislation to implement public country-by-country reporting
October 2022
27 Oct - Australia: Public country-by-country (CbC) reporting proposed in 2022-2023 federal budget
25 Oct - Netherlands: Consultation on implementation of Pillar Two rules
25 Oct - Poland: Updated transfer pricing reporting obligations guidebook
24 Oct - Poland: Transfer pricing measures in legislation amending “Polish Deal”
20 Oct - Romania: Bill implementing public country-by-country (CbC) reporting directive
20 Oct - South Africa: Guidance on definition of “associated enterprises” under transfer pricing rules
19 Oct - KPMG report: Initial observations of OECD report on tax incentives and the global minimum tax
14 Oct - OECD: Updated guidance on implementation of country-by-country reporting
14 Oct - KPMG report: Current state and trends in transfer pricing for intercompany financial transactions
13 Oct - KPMG report: Global formulary apportionment
13 Oct - KPMG report: The arm’s length standard after the pillars
13 Oct - Australia: Consultation paper on BEPS 2.0
12 Oct - KPMG report: Transfer pricing considerations in the age of precision medicine
6 Oct - OECD: Report on tax incentives and the global minimum tax
4 Oct - Philippines: Guidelines and procedures for requesting MAP
3 Oct - KPMG report: In defense of the arm’s length principle
September 2022
30 Sep - OECD: Inclusive Framework on BEPS meeting scheduled for 6 - 7 October 2022
30 Sep - Slovakia: Proposed changes to transfer pricing rules and limitations on deductibility of interest
29 Sep - South Africa: Increased transfer pricing scrutiny
28 Sep - Belgium: Deadline for filing Local file forms is 17 October 2022
28 Sep - Germany: Draft legislation on submission of transfer pricing documentation in tax audit
20 Sep - United States: SEC signals support for country-by-country reporting
8 Sep - Cyprus: Guidance regarding transfer pricing documentation
6 Sep - OECD: Pascal Saint-Amans to retire 31 October 2022
1 Sep - Denmark: Reminder of 6 September deadline for transfer pricing documentation
August 2022
30 Aug - Mexico: Transfer pricing documentation for derivative financial transactions
29 Aug - Poland: Transfer pricing measures in draft bill
25 Aug - OECD: Comments on progress report on Amount A of Pillar One
19 Aug - KPMG report: Comments on progress report on Amount A of Pillar One
19 Aug - KPMG report: European Commission business tax agenda
18 Aug - United States: Tax Court’s determination of transfer pricing method, on remand from Eighth Circuit
12 Aug - Australia: Proposal for increased public reporting of tax and country-by-country information
12 Aug - Malaysia: Effective tax rate; country-by-country reporting data used for transfer pricing purposes
10 Aug - Italy: Tax audits based on cross-border transactions, transfer pricing issues
10 Aug - Korea: Tax reform proposals include transfer pricing documentation and Pillar Two measures
9 Aug - Philippines: Guidance for taxpayers seeking MAP assistance
5 Aug - Australia: Consultation paper, multinational tax integrity and tax transparency
July 2022
29 Jul - Lithuania: Changes to APA rules
26 Jul - KPMG report: Amount B—the forgotten piece of the Pillar One jigsaw
22 Jul - Ireland: BEPS 2.0 implications for aviation sector
20 Jul - UK: Draft legislation to implement Pillar Two published
18 Jul - KPMG report: The diverging paths of Pillars One and Two
18 Jul - Czech Republic: Tax priorities of the Czech EU Presidency
14 Jul - EU: Update on minimum tax directive; priority of new presidency of the European Council
12 Jul - Netherlands: New decree on profit attribution to permanent establishments
11 Jul - OECD: Progress report on Amount A of Pillar One, including revised schedule; public consultation
11 Jul - Cyprus: Transfer pricing documentation legislation
11 Jul - Saudi Arabia: Proposed amendments to transfer pricing bylaws; comments due 30 July 2022
7 Jul - Netherlands: Details about changes in new transfer pricing decree
5 Jul - Poland: Transfer pricing measures in proposed legislation
1 Jul - Netherlands: New transfer pricing decree
1 Jul - KPMG report: Environmental, social, and governance (ESG) and transfer pricing
June 2022
29 Jun - Australia: Proposed amendments to thin capitalisation rules, effect on arm's length debt test
28 Jun - Malta: Update on transfer pricing landscape
27 Jun - UK: Background and implications of delayed implementation of Pillar Two
21 Jun - France: Multinational entity agrees to pay over €1.245 billion to resolve cross-border controversy
17 Jun - EU: Proposal for EU minimum tax directive; update after ECOFIN Council meeting
17 Jun - India: Updated guidance for mutual agreement procedure (MAP)
16 Jun - United States: Transfer pricing settlement initiative program for corporate taxpayers (New Jersey)
15 Jun - OECD: Comments on tax certainty aspects of Amount A under Pillar One
14 Jun - UK: Implementation of Pillar Two delayed
14 Jun - OECD: Tax transparency in Africa 2022
10 Jun - KPMG report: Comments on tax certainty aspects of Amount A under Pillar One
10 Jun - Luxembourg: Transfer pricing implications of new income tax treaty with UK
9 Jun - OECD: New transfer pricing country profiles for Egypt, Liberia, Saudi Arabia, and Sri Lanka
8 Jun - Peru: Approaching deadline for transfer pricing reports for FY 2021
7 Jun - KPMG report: Country-by-country reporting notifications, requirements per country
7 Jun - United States: Future of consumer and retail—transfer pricing perspective
6 Jun - Poland: Finance Minister’s reply to parliamentary inquiry regarding transfer pricing information
1 Jun - United States: Comments submitted to IRS regarding plans to update MAP and APA guidelines
May 2022
27 May - OECD: Tax certainty aspects of Amount A under Pillar One; public consultation
25 May - OECD: Comments on regulated financial services exclusion under Amount A of Pillar One
25 May - Hong Kong: Update on corporate tax issues, including transfer pricing documentation
24 May - EU: Status regarding proposal for EU minimum tax directive
20 May - KPMG report: Comments on regulated financial services exclusion under Amount A of Pillar One
20 May - China: Shenzhen launches first tax and customs collaborative transfer pricing management mechanism
16 May - KPMG report: Public consultation meeting on implementation framework of global minimum tax
9 May - Switzerland: Transfer pricing controversy statistics, including effects of COVID-19
6 May - Netherlands: Considerations for companies in scope of Pillar Two rules
6 May - New Zealand: Consultation on implementation of Pillar Two rules
6 May - OECD: Regulated financial services exclusion under Amount A of Pillar One; public consultation
5 May - KPMG report: BEPS 2.0 implementation considerations for Mexico
4 May - Nigeria: Summary of tax transparency reporting developments
4 May - OECD: Tax transparency in Latin America 2022
4 May - Poland: Transfer pricing reporting changes
3 May - OECD: Comments on extractives exclusion under Amount A of Pillar One
3 May - KPMG report: Comments on extractives exclusion under Amount A of Pillar One
3 May - KPMG report: Transfer pricing planning 2.0
3 May - KPMG report: Why operationalizing transfer pricing is more important than ever
3 May - Switzerland: Tax transparency reporting statistics and global minimum tax update
April 2022
28 Apr - KPMG report: Transfer pricing and the audit committee agenda, implementation steps
22 Apr - OECD: Comments on draft rules for domestic legislation on scope under Amount A of Pillar One
21 Apr - Kenya: Transfer pricing and other tax-related measures in Finance Bill, 2022
20 Apr - KPMG report: Comments on draft rules for domestic legislation on scope under Amount A of Pillar One
20 Apr - KPMG report: Transfer pricing and the audit committee agenda
20 Apr - Mexico: Considerations for maquiladora transfer pricing strategy, given elimination of APAs
20 Apr - Zimbabwe: Extended deadlines for corporate income tax and transfer pricing returns for 2021
14 Apr - KPMG report: Comments on implementation framework of global minimum tax
14 Apr - KPMG report: Comments in response to UK consultation on global minimum corporate tax
14 Apr - OECD: Comments on implementation framework of global minimum tax
14 Apr - OECD: Extractives exclusion under Amount A of Pillar One; public consultation
12 Apr - Brazil: Update on revisions to transfer pricing rules, steps toward OECD Transfer Pricing Guidelines
12 Apr - Zambia: Country-by-country reporting rules for 2021 tax year
11 Apr - Australia: Tax and transfer pricing implications of IBOR reform
11 Apr - Kenya: Proposed reporting requirements for multinational entities
11 Apr - Latvia: Implications of EU “public” country-by-country reporting for Latvian groups
5 Apr - EU: No agreement on revised proposal for minimum tax directive (ECOFIN Council meeting 5 April 2022)
4 Apr - OECD: Draft rules for domestic legislation on scope under Amount A of Pillar One; comments requested
1 Apr - Thailand: Extended deadline for filing transfer pricing disclosure form for 2020 (COVID-19)
March 2022
30 Mar - United States: APMA program, APA statistics for 2021 (IRS Announcement 2022-7)
28 Mar - Angola: Transfer pricing implications of updated list of “large taxpayers”
25 Mar - Canada: Mutual agreement procedure (MAP) statistics for 2020
23 Mar - Mexico: Changes introduced by new transfer pricing regulations
22 Mar - Thailand: Determining related parties when same group of shareholders involved
16 Mar - EU: ECOFIN fails to reach agreement on revised minimum tax directive
14 Mar - OECD: Commentary on Pillar Two model rules for domestic implementation of 15% global minimum tax
8 Mar - OECD: Comments on draft model rules for tax base determinations under Pillar One Amount A
4 Mar - KPMG report: Comments on OECD’s draft rules for tax base determinations under Pillar One
Amount A
3 Mar - Estonia: Amendments to transfer pricing regulation
2 Mar - KPMG report: BEPS 2.0 issues and implications for Latin America
1 Mar - Bulgaria: Withholding tax on “fictitious interest” assessed on interest-free loan (CJEU judgment)
February 2022
28 Feb - Belgium: Tax authorities launch annual round of transfer pricing audits
28 Feb - OECD: Third batch of 2021/2022 updated transfer pricing country profiles
28 Feb - KPMG report: Top concerns for tax leaders on the path forward for BEPS 2.0
28 Feb - Poland: Transfer pricing documentation and financial transactions involving loans
22 Feb - OECD: Comments on draft model rules for nexus and revenue sourcing under Pillar One Amount A
22 Feb - KPMG report: Operational transfer pricing health check
22 Feb - Thailand: Additional country-by-country reporting submission requirements
18 Feb - KPMG report: Initial impressions of draft rules for tax base determinations under Pillar One
Amount A
18 Feb - OECD: Draft rules for tax base determinations under Amount A of Pillar One; comments requested
17 Feb - KPMG report: Benefits of shared service centers in tax processes such as transfer pricing
17 Feb - South Africa: Draft interpretation note on intragroup loans, new transfer pricing guidance
16 Feb - Denmark: Updated guidance on transfer pricing documentation
15 Feb - Australia: Managing cross-border intercompany financing arrangements (court case)
15 Feb - Botswana: Review of transfer pricing rules
15 Feb - Italy: Guidance concerning transfer pricing documentation, penalty protection regime
11 Feb - Barbados: Rules requiring country-by-country reporting enacted
8 Feb - KPMG report: Transfer pricing in a deals context; risks and opportunities for value creation
7 Feb - Czech Republic: Economic challenges potentially affecting transfer pricing
7 Feb - UAE: Transfer pricing implications with introduction of a corporate income tax regime
January 2022
31 Jan - Mexico: APAs no longer available for maquiladora companies
28 Jan - KPMG report: Transfer pricing documentation viewed as ongoing process, not a short-term project
27 Jan - Cyprus: FAQs on intra-group back-to-back financing transactions
25 Jan - India: A decade of the APA program; why it still makes sense
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