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Transfer Pricing News Issue 44 - October 2023

26 October 2023

Original content provided by BDO Global


The OECD recently took what at first glance seems like a big step forward in its drive towards finalisation of its two-pillar framework to address the tax challenges arising from the digitalisation of the global economy: the release of a multilateral convention to implement Amount A of Pillar One. However, technical issues remain, and the convention is not actually open for signature while differences of opinion are ironed out. 

On the same day, the U.S. Department of the Treasury announced a request for public input on the draft convention, the first time Treasury has opened such a consultation on the taxation of the digital economy project. 

In what’s likely to be another multiyear project, the European Commission published a proposal for an EU directive on transfer pricing that would harmonise transfer pricing rules within the EU as part of its Business in Europe: Framework for Income Taxation (BEFIT) package.

Transfer pricing developments in African countries do not always receive warranted attention, but we include reports from Nigeria, where a court has nullified the country-by-country reporting regulations; Burkina Faso, which recently introduced its own CbC reporting rules and advance pricing agreements, and Morocco.



OECD issues progress report on Two-Pillar plan

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OECD Releases Multilateral Convention to Implement Amount A of Pillar One, but Technical Issues Remain

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Burkina Faso - CbC report and APAs introduced

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Morocco - Postpones entry into force of automatic exchange of financial and tax information agreements

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Nigeria - Court nullifies country-by-country reporting regulations

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Asia Pacific                                    

Australia - Transfer pricing issues – Lessons learned at TP Minds Australia 2023

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India - India’s Supreme Court Rules on Transfer Pricing Appeals to High Courts

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