Arm's Length Standard is a bi-monthly transfer pricing newsletter designed to keep senior tax executives updated on transfer pricing developments around the world, featuring news and analyses from the transfer pricing professionals in Deloitte member firms.

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June/July 2009

• Ninth Circuit reverses tax court in Xilinx
• Hong Kong issues guidance on relief from double taxation due to transfer pricing adjustments
• International dispute resolution: Myths of competent authority
• Tenth annual U.S. APA report: Interest in APAs at record high
• U.K. tribunal issues first transfer pricing ruling
• Canada provides waiver relief in transfer pricing reassessments: A good news/bad news proposition
• Greece provides guidance on transfer pricing legislation

April/May 2009

• Mexico’s new transfer pricing reporting obligations will result in increased audit activity
• Former Canadian official shares CRA views on cost sharing, other issues
• Denmark transfer pricing cases on the rise
• New Zealand tax authorities react to changed economic conditions
• U.S. IRS issues tenth annual APA report – Record year for APA requests
• Singapore releases circular on related-party loans and service arrangements
• Creating brand value in the food industry
• Greece introduces transfer pricing documentation rules
• Uruguay issues transfer pricing regulations

February/March 2009
The new Chinese special tax adjustments rules: What are the implications?

December 2008/January 2009
Spain issues new transfer pricing documentation requirements

October/November 2008
OECD issues discussion draft on transfer pricing aspects of business restructurings

August/September 2008
Technical explanation of Canada-U.S. protocol provides guidance on attribution of profits to permanent establishments and arbitration