Recent developments confirm the continued focus of tax administrations on transfer pricing compliance and adoption of country by country reporting, but the changes also illustrate the desire for some tax administrations to create a framework for increased certainty through the advance pricing agreement (APA) process. Among the developments, the US, Australia and Japan have confirmed that the OECD CBCR template will be followed for the required submission of information; the EU Parliament has proposed amendments to the EU administrative cooperation directive to include the sharing of key tax related information on multinational groups; and the EC announced a formal investigation into Luxembourg’s transfer pricing rulings concerning a McDonald’s franchising affiliate in Luxembourg.
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