BDO Transfer Pricing News

Introduction

Over the past few months, tariffs and customs issues have dominated conversations in the international tax arena. For transfer pricing practitioners, customs discussions prompt thoughts of valuation, which can differ for customs and transfer pricing purposes. We include in this issue an article on strategic considerations for customs valuation and transfer pricing, particularly aimed at Canadian businesses exploring the possibility of establishing a U.S. subsidiary to mitigate potential U.S. tariffs. 

Amount B continues to be in the news, with the OECD’s release of a report that consolidates (almost) all guidance issued on the simplified and streamlined approach.

In other developments, the UK tax authorities issued their annual report on transfer pricing statistics for 2023/24. Interestingly, the number of APAs concluded jumped to 27, almost twice the number for the previous year and the highest since 2018/19, and the yield from transfer pricing enquiries was up 9% from the previous year’s total of GBP 1.8 billion. And because the applicability of the UK transfer pricing rules and the documentation requirements for those subject to the rules are not always clear or obvious, we include in this issue a primer on UK transfer pricing and how it works.

The Indian government announced as part of the 2025 Union Budget 2025 the introduction of several transfer pricing provisions, including the concept of block transfer pricing assessments that would cover three-year periods.

Finally, we include a report on the Australian Taxation Office’s updated guidance on the exemptions from country-by-country reporting obligations that is likely to result in fewer exemptions being available after 1 January 2025.