The BEFIT Directive: A Game Changer for Transfer Pricing or an Irrelevant Buzz?

Abstract

The recently proposed BEFIT legislation in the European Union seeks to standardize tax bases and simplify transfer pricing rules for large multinational enterprises. This article delves into potential challenges of this proposition, mainly focusing on its implications from a transfer pricing perspective. Challenges around the coexistence of varying transfer pricing rules, the interplay between BEFIT and Pillar Two, and uncertainties surrounding dispute resolutions are explored.