ARTICLE · 27 SEPTEMBER 2023

New EU Proposal For A Transfer Pricing Directive

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The European Commission on 12 September 2023 issued a legislative proposal for a directive on Transfer Pricing ("EU TP Proposal") which aims for the first time to harmonise EU transfer pricing...

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Kathryn Stapleton

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The European Commission on 12 September 2023 issued a legislative proposal for a directive on Transfer Pricing ("EU TP Proposal") which aims for the first time to harmonise EU transfer pricing ("TP") rules. Like the broader Business in Europe: Framework for Income Taxation ("BEFIT") package of which it is a part, the EU TP Proposal would require unanimous approval from the European Council. Since the changes it would require to the domestic laws of Member States are more limited in scope than other aspects of BEFIT, it is more likely to obtain approval. The Commission wants the proposal transposed by EU Member States by 31 December 2025. Ireland has not yet commented on the proposal.

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