A Trojan Horse?

On 12 September 2023, the European Commission published a proposal for a directive on transfer pricing (hereinafter, the "Proposal" or the "Directive") as part of the package of measures which includes, in particular, the proposed BEFIT directive ("Business in Europe: Framework for Income Taxation" or "Entreprises en Europe : Cadre pour l’Imposition des Revenus") discussed in an article published in the October issue of AGEFI.

The Proposal aims to incorporate key transfer pricing principles into European legislation in order to establish a common approach across Member States.