Transfer Pricing documentation requirements in Europe
The European Transfer Pricing Team at Andersen presents a comprehensive guide designed to offer multinational enterprises (MNEs) a concise overview of critical compliance considerations and deadlines. The landscape of transfer pricing compliance in Europe has witnessed significant activity in recent months. This guide addresses various developments across European jurisdictions, including new transfer pricing documentation requirements, reporting obligations, threshold modifications, and penalties for non-compliance. Examples include Malta, Hungary, Poland, Denmark, and the United Kingdom, which have introduced or updated regulations. Furthermore, some countries have initiated public consultations on impending transfer pricing rules (e.g., the U.K.), while others have provided additional guidance on specific intragroup transactions (e.g., the Netherlands) or adopted the OECD Transfer Pricing Guidelines (TPG) more comprehensively (e.g., Italy, Portugal, Germany). These regulatory changes directly impact MNEs, requiring ongoing efforts to demonstrate adherence to the arm’s length principle in intragroup transactions. The guide underscores the growing need for transparency and robust transfer pricing positions, which are essential for administrative departments navigating this evolving compliance landscape.
Stefano Rossi, Italian partner and coordinator of the European Transfer Pricing department, and his team are available for further clarification.
Click HERE to read the full in-depth study (in English).