Transfer pricing
01020304
With the European Parliament.
Last active 10 Apr 2024
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What this bill does
In plain terms: what it changes and who it affects.
This proposal harmonises EU transfer pricing rules so related companies price cross-border dealings as independent businesses would.
Who it affects
It affects companies and corporate groups with cross-border related-party transactions or permanent establishments in EU Member States, including multinational groups and smaller businesses operating across borders.
Core of the proposal
- Requires Member States to apply a common arm’s length principle for cross-border related-party transactions.
- Defines associated enterprises using management influence, 25% voting, capital, or profit thresholds, and permanent establishments.
- Sets rules for primary, corresponding, downward, and compensating transfer pricing adjustments.
- Requires recognised transfer pricing methods, comparability analysis, interquartile ranges, and transfer pricing documentation.
Key provisions
- Takes effect
- The Directive enters into force on the twentieth day following publication; Member States must apply transposing rules from 1 January 2026.
- Transitional law
- Member States must adopt and publish implementing national rules by 31 December 2025, before applying them from 1 January 2026.
Latest update
26 May 2026The most recent development in this bill's progress.
Moved to European Parliament
Documents
3 recentSourcesOEIL