BDO Global Transfer Pricing News

Issue 45 | December 2023

As 2023 draws to a close, the OECD injected some drama into the Pillar One saga with its 11th hour announcement, in a terse two-paragraph statement, that the time frame to finalise the text of the multilateral convention to implement Pillar One would be delayed to the end of March 2024 from the original December 2023 deadline. 

The OECD’s announcement did not mention Amount B of Pillar One, which has been the subject of two public consultations but has yet to be finalised. We include two articles on Amount B in this issue of Transfer Pricing News, one a general assessment of the proposal and the second a review from a South African perspective. 

The OECD also released its annual mutual agreement procedure (MAP) statistics for 2022, which revealed an increase in the number of MAP cases opened in 2022, but a decrease in the number of cases closed.

Not all transfer pricing developments revolved around the OECD or Pillar One. See, for example, our articles on France’s amendments to its transfer pricing regime, a report on the U.S. IRS’s newly launched campaign to bring U.S. distributors of foreign corporations into transfer pricing compliance, or an Australian reminder to importers who purchase goods from overseas related parties that they may have customs obligations when they make transfer pricing adjustments. And of course, we discuss the final stages of Brazil’s alignment of its transfer pricing rules with the international standard, a process that was years in the making.

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