What Proposal for a Council Directive on Transfer Pricing requires
This proposed directive requires multinational enterprises operating in the EU to ensure that the terms and conditions of their cross-border transactions between associated enterprises are consistent with the arm's length principle (ALP), as defined in Article 3. It aims to create a common EU framework for applying the ALP, including rules on primary, corresponding, and compensating adjustments, to prevent profit shifting and ensure fair taxation.
Pillar: Tax & Transfer Pricing · Authority: European Commission · Version: 1.0.0 · Last updated:
Primary source: https://taxation-customs.ec.europa.eu/taxation/business-taxation/transfer-pricing-eu/proposal-harmonised-transfer-pricing-rules-eu_en
SHA-256 integrity: fd87b96583b98e4346b4a3ad22c46b0cb7576453899666c211b2d87e393e6c4e
Primary Citations — 6 traced to source
- Proposal for a Council Directive on Transfer Pricing, Article 3 - The arm's length principle
- Proposal for a Council Directive on Transfer Pricing, Article 5 - Comparability analysis
+ 4 more citations (full bibliography, deterministic workflow, actionable schema and crosswalks) included in the vault unlock — $0.01 via Skyfire / L402 / Direct Base USDC.
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