European Union: The Commission proposes new transfer pricing initiatives

In brief

On 12 September 2023, the EU Commission published a number of important transfer pricing initiatives both as part of the BEFIT Directive proposals and in the form of a standalone Transfer Pricing Directive.

These Directives, if adopted, should move the needle toward both the standardization of transfer pricing rules within EU member states, thereby reducing intra-EU transfer pricing disputes, and the simplification of compliance burdens. On the whole, these measures should be seen as a positive development for businesses.

It is clear that transfer pricing continues to be a key area of focus for many tax authorities. With proposed changes being consulted on in a number of jurisdictions (including the UK), alongside the ongoing work of the Organisation for Economic Co-operation and Development (OECD) in relation to Pillar 1 Amount B, there will be a significant amount of change in this area for in-house tax teams to consider.

Stakeholders have been asked to provide feedback on the new proposal by 15 November 2023


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