A Closer Look at the European Commission Proposal for Harmonized Rules for Transfer Pricing

Abstract

In this article, the authors provide the background and objection of the EU TP Directive, and analyse the proposal and its position in respect of other international tax developments. They conclude that the TP Directive is expected to increase tax certainty for taxpayers across the European Union, as the CJEU would become the court of highest instance for the application of the arm’s length principle. Unfortunately it will take substantial time to reach the increased certainty.