BDO Transfer Pricing News - Issue 36

We are pleased to bring you this issue of BDO’s Transfer Pricing News, produced in close cooperation with our colleagues from the BDO network. If you would like more information on any of the featured articles, or would like to discuss their implications for your business, please contact the person listed under each article. 

Transfer pricing rules around the world continue to evolve. While some countries are attempting to streamline their transfer pricing regimes, the general trend seems to point in the opposite direction. For example, Argentina recently introduced a simplified transfer pricing regime to reduce the administrative burden on taxpayers. Similarly, China has introduced a simplified procedure for unilateral advance pricing agreements that sets time limits for the Chinese tax authorities to complete the application process.

The UK, on the other hand, may be on a path to increased complexity in transfer pricing. A recently concluded government consultation included proposals that, if adopted, would effectively mean that for the first time a transfer pricing master file and UK local file would be mandatory for the largest multinational enterprises (MNEs).

Not all transfer pricing issues arise out of new transfer pricing legislation, or tweaks to existing rules. For example, the phase-out of the London Interbank Overnight Rate—LIBOR—scheduled for the end of 2021, is likely to have a significant impact on companies that will have to identify intercompany agreements containing LIBOR references and undertake the processes to modify those agreements.

Finally, we include in this issue a survey report on the treatment of intragroup and low-value-adding services for transfer pricing purposes in the BRICS countries—Brazil, Russia, India, China and South Africa.

The material discussed in this newsletter is intended to provide general information only and should not be acted upon without first obtaining professional advice tailored to your particular needs.


  • International
    • Supply chain planning - Beyond COVID
    • Dealing with the transfer pricing complications arising due to COVID-19
    • Adapting supply  chains – More than moving functions
  • Argentina: New simplified   transfer pricing regime introduced
  • Australia: ATO releases compliance guidance for intangible arrangements with cross-border related parties
  • BRICS: Intragroup and   low-value-adding services: A BRICS perspective
  • China: New simplified procedure for unilateral APAs introduced
  • Germany: Tax Bill AbzStEntModG   enters into force
  • United Kingdom: Major transfer pricing documentation changes proposed
  • United States: Transfer pricing considerations for LIBOR transition

Read transfer pricing news