America executes 86 APAs in 2016, Indian bilateral applications dominate US filings

US IRS issues statutory report on Advance Pricing and Mutual Agreement Program (APMA Program) for calendar year 2016, highlights signing of 86 APAs (21 unilateral and 65 bilateral); 34% of

Apr 03, 2017

New Zealand proposes interest rate cap on related loans, rule targeting PE avoidance

New Zealand releases 3 discussion documents seeking submissions on a package of measures to counter BEPS, namely, i) Transfer pricing and permanent establishment (“PE”) avoidance, ii) Strengthening interest limitation rules

Mar 14, 2017

New Zealand to incorporate BEPS Actions 8-10 revisions to align TP-rules with economic substance

New Zealand releases discussion document proposing to introduce a package of measures, in addition to other BEPS related measures, to address transfer pricing (TP) and permanent establishment (PE) avoidance; In

Mar 10, 2017

Public CbCR to require qualified majority rather than unanimity : European Parliament

European Parliament’s Committee on Legal Affairs issues public opinion on legal basis of EC proposal relating to public Country-by-Country (CbC) reporting; Concludes that the introduction of public CbCR being an

Feb 20, 2017

Singapore provides TP-documentation exemption for related-party loans adhering to 'indicative margins'

Singapore IRAS publishes fourth edition of its e-Tax Guide on transfer pricing, updates guidance on arm’s length principle and functional analysis, TP documentation, MAP and APA processes and related party

Jan 17, 2017

45 key takeaways from European Commission's Apple State aid ruling

European Commission (EC) decision in the Apple State aid case concludes that tax rulings of 1991 and 2007 issued by Irish Revenue in favour of 2 Apple sales and marketing/manufacturing

Dec 23, 2016