BDO Transfer Pricing News

Issue 55 — June 2026

This issue of Transfer Pricing News brings together key developments shaping global transfer pricing risk, documentation expectations and intragroup pricing outcomes:

• Australia: Recent updates to guidance on transfer pricing for inbound distribution arrangements broaden the concept of an “inbound distributor,” revise expected operating margin benchmarks and introduce a new “white zone” category, allowing eligible taxpayers to be excluded from the standard risk assessment.
• EU: The CJEU delivers long awaited clarity on the VAT treatment of intragroup transfer pricing adjustments, confirming that year end pricing adjustments do not automatically constitute consideration for services unless a reciprocal legal relationship exists.
• Luxembourg: The Administrative Tribunal reaffirms that guarantee-type support warrants arm’s length remuneration, not a full reallocation of financing returns, absent evidence of control over core financing functions.
• New Zealand: Inland Revenue raises the bar on transfer pricing documentation, signalling heightened expectations for localisation and evidentiary quality under its multi-year transfer pricing compliance programme.
• United Arab Emirates: Economic shifts are prompting multinational businesses to re-evaluate profit, cost and risk allocations across jurisdictions.

Read more about the news on the website → BDO Global

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Source: BDO Global