Transfer Pricing News | Issue 36 – August 2021

Transfer pricing is increasingly influencing significant changes in tax legislation around the world. The 36th issue of BDO’s Transfer Pricing news focuses on significant international developments and recent developments from Argentina, Australia, China, Germany, the United Kingdom and the United States.

Transfer pricing rules around the world continue to evolve. While some countries are attempting to streamline their transfer pricing regimes, the general trend seems to point in the opposite direction. For example, China has introduced a simplified procedure for unilateral advance pricing agreements that sets time limits for the Chinese tax authorities to complete the application process.

The UK, on the other hand, may be on a path to increased complexity in transfer pricing. A recently concluded government consultation included proposals that, if adopted, would effectively mean that for the first time a transfer pricing master file and UK local file would be mandatory for the largest multinational enterprises (MNEs).

Finally, a survey report on the treatment of intragroup and low-value-adding services for transfer pricing purposes in the BRICS countries—Brazil, Russia, India, China and South Africa – is also included in this issue. 

The material discussed is intended to provide general information only and should not be acted upon without first obtaining professional advice tailored to your particular needs.

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Content adapted from BDO Global.

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