Navigating the Transfer Pricing Pitfalls and Opportunities of Pillar Two: Part 1 – Transfer Pricing Adjustments

This article highlights some of the key areas where multinational groups may face double (non-)taxation when facing the interplay between Pillar Two and transfer pricing adjustments. Practical financial examples are used to illustrate the impact as well as the actions multinational groups may consider taking to mitigate the impact hereof. Recommendations are equally made towards policymakers to alleviate the impact of certain (unintended) consequences from the joint application of Pillar Two and transfer pricing principles. Topics covered are book-to-provision adjustments, the timing of transfer pricing adjustments and the impact of mutual agreement procedures from a Pillar Two perspective.