BDO Transfer Pricing News

Introduction

After years during which the OECD’s two-pillar framework has been the main topic of conversation in international tax and transfer pricing circles, a new topic is gaining prominence – the adoption of public country-by-country reporting (CbCR) requirements. In a push for greater tax transparency, the EU took the lead, and adopted a public CbCR directive that entered into force on December 21, 2021, and applies to fiscal years beginning on or after 22 June 2024. Australia has now followed that lead and recently introduced its own version of public CbCR legislation.

The two-pillar framework – and specifically Amount B of Pillar One -- is still an important issue for transfer pricing. The OECD recently released additional guidance on Amount B, providing answers to questions that had been left unanswered in its February 2024 report. We also include a report in this issue on Amount B's potential implications for South Africa.

Advance pricing agreements are another perennial transfer pricing topic, and in this issue we report on India’s record number of APAs completed during fiscal year 2023-24, as well as the U.S.’s annual report, which shows that significantly more APAs were executed during 2023 than during the prior year.

Two UK articles round up our coverage in this issue – an analysis of the recent Court of Appeals rulings in the Kwik-Fit and BlackRock cases.