On 4 June, the European Commission (EC) adopted a “communication” that includes guidelines on three aspects of the treatment of transfer pricing transactions:
- The risk management in dealing with transfer pricing
- The application of secondary adjustments
- The use of compensating adjustments
According to the EC release, these guidelines are relevant in the context of the ongoing OECD work on the Base Erosion and Profit Shifting project (BEPS).
The transfer pricing guidelines are drawn from the work of the EU Joint Transfer Pricing Forum (JTPF), as established by the EC to improve the functioning of the Single Market and to allow for better corporate tax coordination.
This communication also provides an update update on the implementation of the JTPF work programme (PDF, 773 KB), which runs until March 2015.
Read more about these new transfer pricing guidelines in a related release in the form of "frequently asked questions" (PDF, 56 KB) (FAQs).
For further information, please do not hesitate to contact us.
Any tax advice in this communication is not intended or written by KPMG to be used, and cannot be used, by a client or any other person or entity for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing, or recommending to another party any matters addressed herein.
The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.