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The EU’s TP directive proposal: effective reform or a Hail Mary pass?
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THE EU’S TP DIRECTIVE PROPOSAL: EFFECTIVE REFORM OR A HAIL MARY PASS?


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Ingrid Faxing, 
Henri Ahtiainen
February 29, 2024
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INGRID FAXING AND HENRI AHTIAINEN OF SKEPPSBRON SKATT ANALYSE A PROPOSAL TO
INCORPORATE THE OECD TRANSFER PRICING GUIDELINES INTO EU LAW AND QUESTION
WHETHER IT WILL BECOME A REALITY AFTER SEVERAL OBJECTIONS

The European Commission (the Commission) presented its Proposal for a Council
Directive on Transfer Pricing (the TP Directive) in September 2023, as part of
the BEFIT package as set forth in the Proposal for a Council Directive on
Business in Europe: Framework for Income Taxation (BEFIT) (the BEFIT Directive).

The TP Directive aims at incorporating the arm’s-length principle (ALP) and the
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax
Administrations, 2022 (the OECD Guidelines) into EU law.

The rationale for the proposal is born from the fact that although most EU
member states are members of the OECD, the status, role, and interpretation of
the OECD Guidelines differs between member states. The provisions described in
the TP Directive must be implemented by member states by December 31 2025 and
are proposed to apply from January 1 2026. Adoption of the directive requires
unanimity in the European Council, where all member states are represented, as
stipulated in Article 115 of the Consolidated Version of the Treaty on the
Functioning of the European Union.

This article describes and analyses the implications of introducing transfer
pricing (TP) rules to EU law for the balance of competences and the application
of the ALP within the EU.


THE EU AND THE ARM'S-LENGTH PRINCIPLE

The most significant impact of the TP Directive on member states is the
incorporation of the ALP into EU law. The ALP and an arm's-length result are
defined in Article 3 of the TP Directive, which broadly mirrors the definition
in the OECD Guidelines. As mentioned above, there have been differences in the
interpretation of the ALP between member states but also between member states
and EU institutions.

For instance, in the Fiat Chrysler Finance Europe (FFT) state aid case, the
Commission applied an ALP that deviates from the one defined in Luxembourg law
by taking into account only the OECD Guidelines. According to the Court of
Justice of the European Union (CJEU), this constituted a fictitious and
erroneous framework for the assessment of state aid.

The court maintained that in the absence of harmonisation within the internal
market, the member states retain the discretion and competence for the
determination of arm’s-length pricing. The detailed principles and rules of
national law must therefore be taken into account in determining the reference
system for determining whether there is a selective advantage.

Although there may be some consensus among member states that intra-group
transactions should be assessed for tax purposes as if they had been carried out
between independent companies, only national rules are relevant for analysing
whether transfer prices deviate from the ALP. Hence, parameters and rules
outside the national tax system cannot be considered unless explicitly referred
to in that system. This approach has since been confirmed in several judgments
of the CJEU regarding state aid issues; namely, the Engie case (C 451/21 P and C
454/21 P) and the Amazon case (case C 457/21 P).


THE TP DIRECTIVE

As mentioned, the TP Directive incorporates the ALP and TP rules into EU law.
There is no threshold linked to the rules; however, a common definition of what
should be considered a controlled company has been included in the directive
(Article 5). Furthermore, the TP Directive renders the latest version of the
OECD Guidelines legally binding on the member states. Considering that the OECD
Guidelines are updated continuously, further updates of the guidelines must be
accepted through approval in the framework of the OECD Committee on Fiscal
Affairs.

The Commission additionally retains the right to propose amendments to the TP
Directive to reflect changes in the OECD Guidelines.

The directive contains rules on the application of comparability analysis and
arm's-length ranges. According to the directive, the taxable result of a
multinational entity shall not be adjusted if it falls within the interquartile
range unless it can be proved that a different position within this range is
justified by the facts and circumstances of individual cases.

If the result of a controlled transaction falls outside the arm's-length range,
it shall be adjusted to the median of the range unless it can be proved that
another position in the range provides an arm's-length price (Article 12). This
contrasts with the OECD Guidelines, which state that the whole range (i.e., not
just the interquartile range) can be arm's length. The application of
arm's-length ranges from comparability analysis also differs between member
states where, for example, in some states it is acceptable to adjust to the
nearest quartile while others advocate an adjustment to the median.

Regarding TP documentation, Article 13 requires member states to ensure that
taxpayers can provide information and analysis to confirm that they have applied
arm’s-length pricing to their intra-group transactions. In addition, the
Commission is empowered to supplement the TP documentation rules by establishing
common templates, language requirements, which companies that are subject to
mandatory documentation requirements and deadlines.

The TP Directive also includes rules regarding corresponding and compensating
adjustments (articles 6.1 and 7).


REACTIONS FROM MEMBER STATES AND ORGANISATIONS

The feedback on the TP Directive from member states has been scarce, with
feedback mainly on the BEFIT Directive.

The Swedish government believes that the differences between the member states'
interpretation and application of the ALP are overestimated and that disputes
often arise because the member states make diverse assessments of the
circumstances in specific cases rather than the application of the OECD’s
recommended approaches. The government also believes that when TP rules are
applied internationally, global solutions are preferable to solutions limited to
the EU level.

The European Parliament presented its draft legislative resolution on the TP
Directive on 14 November 2023, in which the rapporteur included a sunset clause
with the aim of phasing out the application of the ALP and instead implementing
an allocation mechanism of taxes according to a certain allocation key (similar
to the previous common corporate tax base and common consolidated corporate tax
base proposals).

Under the sunset clause, the TP Directive will cease to apply to groups subject
to the BEFIT rules in 2035 and to all multinational groups operating in the EU
(except for transactions with third countries) in 2040 (see page 33 and Article
19a of the Draft European Parliament Legislative Resolution on the proposal for
a Council Directive on Transfer Pricing).

Notwithstanding the above, according to the European Parliament’s press release
on 22 February, the directive received broad support among the members of the
European parliament (MEP). Specifically, the shortened deadline for entry into
force (2025 instead of 2026) was widely supported, along with re-establishment
of the EU Joint Transfer Pricing Forum and close alignment of the directive to
the OECD Guidelines.


SKEPPSBRON SKATT’S COMMENTS

Should the directives presented by the Commission in the BEFIT package be
adopted by the member states, it would imply major changes for the member states
and companies within the EU. The taxation rights of the member states will
become more limited and the Commission and the CJEU will be given a greater
mandate to assess corporate tax issues, including TP.

There are possibilities and challenges presented by the TP Directive. Adoption
of the directive would entail a common definition of the ALP and a common view
on the status of the OECD Guidelines. The Commission would also be given a
mandate to draft rules regarding TP documentation. Joint interpretation of the
ALP and a standard format within the EU for documentation is likely to help to
facilitate the handling of TP issues for multinational groups within the EU.
Currently, most EU member states apply the OECD standards in terms of TP
documentation, but there are still differences in the type of information to be
included.

The introduction of the TP Directive would also enable the EU courts to assess
legal issues linked to the ALP. This could further simplify navigating local TP
practices between EU jurisdictions for multinational groups.

Furthermore, the TP Directive establishes regulations for primary and
corresponding, as well as compensatory, adjustments that will play a significant
role in avoiding double taxation. Having an efficient system for dealing with
double taxation on the internal market is, of course, of significant importance.
It would, however, be welcomed if the dispute resolution mechanisms that
currently exist within the EU were reviewed and improved, as they do not
function optimally at present.

With regard to illegal state aid, the Commission has thus far assumed that there
is a general definition of the ALP within the EU that it has applied in various
cases. It is reassuring that the CJEU put an end to this, since the rules on
state aid are clearly based on the national reference system. Had the CJEU not
protected this principle, it would have greatly undermined the member states'
fiscal sovereignty and decision-making power regarding direct taxes. The
Commission would have otherwise received a ‘back-road’ opportunity to diminish
the sovereignty of the member states in terms of direct taxation, which goes
against EU law.


POTENTIAL APPLICATION OF THE TP DIRECTIVE BY MEMBER STATES

Should the TP Directive be adopted, all member states will be given the
opportunity to assess whether TP rules are something they are willing to give up
control over. However, it is uncertain whether the TP Directive will solve the
challenges regarding the ALP and state aid rules, such as in the FFT
proceedings, since differences between member states may still arise after
possible approval of the TP Directive.

Nonetheless, the Commission should be given the possibility to challenge
national practices that clearly deviate from the OECD Guidelines. This could
lead to the Commission possibly having opened ‘Pandora's box’ in terms of treaty
claims against individual member states and a significant increase in the number
of TP proceedings in the CJEU.

The TP Directive would entail significant changes in the national legislation
for many member states. For example, from a Swedish perspective, the TP
Directive would imply major changes regarding the status of the OECD Guidelines
as a legal source, which has been historically debated in Swedish doctrine.

The TP Directive could also mean that certain common practices regarding
adjustments to the interquartile range, the role of intra-group agreements, etc.
can be deemed to deviate from the TP Directive and thus be questioned by the
Commission. Considering that the OECD Guidelines are updated continuously, it
would also be desirable for the TP Directive to provide clarity on whether new
guidelines should be applied retroactively, to ensure consistent application
between member states.

Furthermore, the TP Directive could entail that tax agencies have stronger
support for the recharacterisation of intra-group transactions, which is a
controversial topic in Sweden, where opinions are often divided between
practitioners on whether the income adjustment rule allows recharacterisation of
transactions.

The European Council has, as mentioned, proposed that the TP Directive should
include a sunset clause, which would entail an evident departure from the OECD
Guidelines and the principles countries have globally agreed upon. Differences
in TP rules within the EU and towards third countries are detrimental, as it
would have a negative effect in terms of administration for multinational groups
rather than reduce such obligations. Global cooperation and reference to the
OECD Guidelines should be the guiding principle for the EU in TP matters.


NEXT STEPS FOR THE TP DIRECTIVE

The final date for member states to provide their comments was 16 February 2024
and since several countries have objected to the proposals, changes can be
expected. For the TP Directive to be adopted, unanimous approval is required
from all member states. Following the feedback from the members of the economic
and monetary affairs, the opinion of MEP will be confirmed by the Parliament’s
plenary before passing it to the Council for adoption of the definitive act.

Harmonisation in TP could be positive but given the differences that exist
between the member states, and the focus they have on protecting their tax base,
a great deal of uncertainty remains around the likelihood of the TP Directive
becoming a reality.


TOPICS

SponsoredTransfer PricingEuropean UnionSkeppsbron SkattTransfer Pricing Guide
2024Transfer Pricing Guide
Ingrid Faxing
Partner Skeppsbron Skatt (Taxand Sweden)
Contact
 * email
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Ingrid has over 11 years of experience within transfer pricing and advises
clients in various sectors, such as industrial, life science and healthcare, IT,
and energy. She is regularly engaged in advising on business restructurings,
planning, policies, transactions involving intangible assets, and tax
litigation.

Besides Ingrid’s work as a tax adviser, she has published numerous articles in
Swedish and international tax journals. Ingrid is also part of the team behind
Sustainable Tax, a business area within sustainability, tax, and financial
reporting.
Henri Ahtiainen
Transfer pricing adviser Skeppsbron Skatt
Contact
 * email

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Certain information (like an IP address or device capabilities) is used to
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facilitate the transmission of the content or ad to your device.

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MATCH AND COMBINE DATA FROM OTHER DATA SOURCES 379 PARTNERS CAN USE THIS PURPOSE

Always Active

Information about your activity on this service may be matched and combined with
other information relating to you and originating from various sources (for
instance your activity on a separate online service, your use of a loyalty card
in-store, or your answers to a survey), in support of the purposes explained in
this notice.

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LINK DIFFERENT DEVICES 336 PARTNERS CAN USE THIS PURPOSE

Always Active

In support of the purposes explained in this notice, your device might be
considered as likely linked to other devices that belong to you or your
household (for instance because you are logged in to the same service on both
your phone and your computer, or because you may use the same Internet
connection on both devices).

List of IAB Vendors‎

IDENTIFY DEVICES BASED ON INFORMATION TRANSMITTED AUTOMATICALLY 508 PARTNERS CAN
USE THIS PURPOSE

Always Active

Your device might be distinguished from other devices based on information it
automatically sends when accessing the Internet (for instance, the IP address of
your Internet connection or the type of browser you are using) in support of the
purposes exposed in this notice.

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