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The interaction between customs and transfer pricing has been a perennial issue for transfer pricing practitioners, but in 2025, given the heightened interest in tariffs, the issue has gained urgency and brought transfer pricing to the fore. In this issue of BDO’s Global TP News, we include a Canadian article on the customs/transfer pricing interplay, which notes that artificially lowering transfer prices to minimise tariff liabilities may trigger regulatory investigations and result in tax reassessments by the relevant authorities. The EU Court of Justice recently issued a landmark ruling on this topic, offering much needed clarity on customs valuation processes in relation to complex price adjustments in cross-border transactions.
Another evergreen issue in the transfer pricing world is the question of what constitutes an arm’s length amount of debt. The Australian Taxation Office recently published guidance on this topic, which adopts a “risk zone” approach with a range of colour-coded risk outcomes. Georgia is also grappling with this issue, and recently introduced regulations governing the proper delineation of controlled loan transactions.
Georgia also has introduced legislation making country-by-county (CbC) reporting an obligation effective for the 2025 fiscal year. CbC reporting obligations have been in place for some years now, but the reports have become more significant because of the role they play in determining whether a multinational entity is eligible for Pillar Two safe harbours. In an effort to improve the quality of CbC reports, the OECD recently published a list of common errors MNE groups make when preparing these reports.
We round out our issue with two articles on new transfer pricing legislation – one from Denmark, and the other one from the UK.
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Another evergreen issue in the transfer pricing world is the question of what constitutes an arm’s length amount of debt. The Australian Taxation Office recently published guidance on this topic, which adopts a “risk zone” approach with a range of colour-coded risk outcomes. Georgia is also grappling with this issue, and recently introduced regulations governing the proper delineation of controlled loan transactions.
Georgia also has introduced legislation making country-by-county (CbC) reporting an obligation effective for the 2025 fiscal year. CbC reporting obligations have been in place for some years now, but the reports have become more significant because of the role they play in determining whether a multinational entity is eligible for Pillar Two safe harbours. In an effort to improve the quality of CbC reports, the OECD recently published a list of common errors MNE groups make when preparing these reports.
We round out our issue with two articles on new transfer pricing legislation – one from Denmark, and the other one from the UK.
Content
- Australia: What Constitutes an Arm’s-Length Amount of Debt? The ATO Weighs In
- Canada: From compliance to competitive advantage: Transfer pricing and supply chains
- Denmark: New Transfer Pricing Documentation Legislation
- European Union: Landmark Court of Justice Decision Clarifies Customs, Transfer Pricing Interaction
- Georgia:
- Germany:
- OECD: Report Highlights Common Errors in Country-by-Country Reports
- United Kingdom: HMRC Publishes Draft Legislation on Transfer Pricing, PE, DPT Reforms
Go to this edition