Study on comparable data used for transfer pricing in the EU : final report

Improving the transfer pricing regulations and practices is a priority for policy makers across OECD, G20 and EU countries. The European Commission has addressed this issue as part of its overall Action Plan for fair and efficient corporate taxation in the EU. In this context, the European Commission sees a strong need to assess the state of play and improve the knowledge of good practices on terms and conditions under which intra-group prices are set up. The focus of the study is on the assessment of the availability and quality of market data ('comparables') used in this context in the EU-28 Member States. More specifically, the present study was commissioned with the aim of: Assessing and evaluating situations characterizing the lack and / or non-reliability of comparables ; Developing and envisaging EU-tailored solutions and possible adjustments taking into consideration some advantages and assets offered by the EU internal market ; Contribute to strengthening and effectively implementing an improved EU transfer pricing framework and fight against aggressive tax planning.