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  • BDO Transfer Pricing News

    Issue 42


BDO Transfer Pricing News

14 April 2023

Original content provided by BDO

The digital economy story is not done

Earlier this year, the OECD released a consultation document on Amount B, the less-known second part of Pillar One. BDO’s Global Transfer Pricing team submitted comments on the consultation document, concluding that for Amount B to meet its goals of reduced taxpayer compliance costs and enhanced tax certainty, the Inclusive Framework should broaden the scope of activities that constitute acceptable baseline marketing and distribution activities. Moreover, the two pricing methodologies currently under discussion require much additional work to avoid imposing excessive administrative burdens for MNEs and tax authorities.


Germany tightens the requirements

In other important news, Germany recently enacted legislation that tightens the country’s transfer pricing documentation requirements by allowing taxpayers only 30 days – rather than 60 under current rules – to comply with auditors’ request for documentation of the arm’s length pricing of intragroup cross-border transactions.  The new rule will apply to tax audits that commence after 1 January 2025.


HMRC transfer pricing enforcement activity statistics show impact of COVID

Annual transfer pricing statistics are always interesting, as they provide some insight into otherwise opaque systems. The UK’s HM Revenue & Customs (HMRC) recently released annual transfer pricing and diverted profits tax (DPT) statistics for the year ended 31 March 2022, which show that during the 2021/22 tax year,  HMRC settled a record 175 transfer pricing enquiries, and that the time it took to resolve those cases fell slightly, although the average dispute still takes 34 months to resolve. The number of advance pricing agreements (APAs) HMRC agreed with multinationals in the year dropped to just 20, whereas the number of companies applying for an APA increased to a record 40. Interest in APAs is notable, given that it now takes nearly five years on average to finalise an APA in the UK.


  • Brazil: New guidance on election to apply new transfer pricing rules
  • Germany: Modernisation of procedural transfer pricing law
  • International: BDO submits comments to OECD on Pillar One Amount B 
  • Israel: Transfer pricing form updated
  • United Kingdom
    • HMRC transfer pricing enforcement activity statistics show impact of COVID
    • Transfer pricing documentation changes introduced effective April 2023
  • United States: Prepare your transfer pricing policies for the coming inflation storm

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