On 15 September 2015 proposed legislation was published, which contains modifications to the 1969 Dutch Corporate Income Tax Act in order to implement the three-tiered transfer pricing documentation requirements as recommended by the OECD in the new Chapter V to the OECD Transfer Pricing Guidelines, published in September 2014 under the Base Erosion and Profit Shifting (BEPS) project.

The global tax environment is rapidly changing. Tax strategies, which have been legal and common for many years, are increasingly regarded as unacceptable. The public perception that corporates artificially shift earnings to low tax jurisdictions and default on their “social contract” has catapulted transfer pricing to the centre of the corporate social responsibility debate.

On August 12 the IRS issued final guidance (Rev. Proc. 2015-40) significantly updating procedures for requesting and obtaining an advance pricing agreement (APA) from the Advance Pricing and Mutual Agreement (APMA) program. All new APA requests will need to be filed under these “new procedures”, however, an APA request may be filed under the prior procedures (Rev. Proc. 2006-9), if a new and substantially complete request is filed no later than December 29, 2015.

The Canada Revenue Authority (CRA) has just released its 2014-2015 APA program report (covering the 12 months to 31st March 2015). The report provides statistics in respect of all APA cases managed during the period. For the full report, see:

With the OECD's BEPS deliverables to be finalised for the G20 Finance Ministers in a few weeks time, the clock is now ticking loudly for corporates to organise their TP Records and prepare for Country-by-Country-reporting (CBCR).

China's State Administration of Taxation (SAT) has been busy during recent months pushing ahead with its own plans to update/revise a series of domestic tax laws and regulations as well as Sino-foreign tax treaties.

Yesterday (21/10/15), the European Commission (EC) announced in its final decisions in respect of the formal state aid investigations into transfer pricing agreements secured under tax rulings between:

October 5 was BEPS day. The OECD published the long-awaited final versions of all its deliverables on the project against Base Erosion and Profit Shifting. Key deliverables of critical importance to transfer pricing (TP) are the revised chapters V and VI of the OECD Transfer Pricing Guidelines on TP documentation and intangibles, together with related guidance on “Aligning TP Outcomes with Value Creation”.