Position

Position Paper on the Transfer Pricing Directive Proposal

  • Technology Industries of Finland agrees with the Commission that tax compliance is currently too burdensome and complex. However, TIF does not believe the TP directive (together with the BEFIT directive) would ease the complexity and burden of tax compliance, but in fact increase it.
  • EC’s goal is to unify the interpretation of the OECD's transfer pricing guidelines. This should not be done by creating parallel EU definitions deviating from the OECD transfer pricing guidelines. The OECD's comprehensive TP guidelines, widely applied around the world, although not simple, they are well established. The current transfer pricing rules and arm’s length principle should be kept in force and prioritized.
  • If the EU wants to unify the application of the OECD's transfer pricing guidelines, it should rather be reached by supporting the EU Member States to implement the OECD's regulation into their own national legislation as a statutory source of law.

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