International regulatory developments and TP impact assessments

International tax and transfer pricing rules continue to evolve, with developments such as Public Country-by-Country Reporting, Pillar Two and Pillar One Amount B changing how multinational groups report, evidence and defend their transfer pricing positions. We help clients assess the practical impact of these developments on their transfer pricing policies, documentation, data, reporting obligations and audit-readiness.

Why this matters

Transfer pricing is increasingly assessed through multiple lenses: local documentation, public tax transparency data, CbCR information, Pillar Two safe harbour analyses, financial reporting data and tax authority risk assessment tools. This increases the importance of consistency between the transfer pricing policy, the master file, local files, CbCR data, statutory accounts and public disclosures.

Public CbCR illustrates the broader shift towards increased tax transparency and external scrutiny of multinational groups’ tax positions. Information that was historically reported confidentially to tax authorities will, for many large groups, become publicly accessible and may be reviewed by a wider stakeholder group, including auditors, investors, media, civil society and tax authorities. In this context, it is important that Public CbCR disclosures are aligned with the group’s operating model, transfer pricing policies, master file narrative and broader tax governance framework, in order to manage tax, reputational and governance risks.

Pillar Two also increases the importance of reliable CbCR and financial data, particularly where groups seek to rely on Transitional CbCR Safe Harbour rules. Amount B may, in turn, affect the way certain baseline distribution activities are analysed, priced and documented. These developments do not replace transfer pricing analysis, but they do require groups to reassess whether existing policies, data and documentation remain fit for purpose.

How we help

• Assess the impact of new developments: identify how Public CbCR, Pillar Two, Amount B and other international developments may affect the group’s transfer pricing position, reporting obligations and risk profile.
• Map jurisdictional requirements and next steps: prepare a practical country-by-country overview of relevant regulatory developments, local implementation rules, reporting deadlines, publication requirements and key decisions, supported by a clear compliance roadmap.
• Review consistency across reporting layers: assess alignment between the transfer pricing policy, master file, local files, CbCR data, Public CbCR disclosures, statutory accounts and Pillar Two data inputs.
• Support Public CbCR readiness: help groups assess scope, data availability, reporting approach, local publication requirements and the consistency of the public tax narrative.
• Analyse the TP impact of Pillar Two: review the interaction between transfer pricing, CbCR data, safe harbour analyses and jurisdictional profitability outcomes.
• Assess Amount B relevance: determine whether routine distribution arrangements may fall within scope of Amount B and what this means for pricing, benchmarking and documentation.
• Assess readiness and risk exposure: identify jurisdictions, entities or transaction flows that may attract increased scrutiny based on public reporting, profitability patterns or data inconsistencies.
• Coordinate across jurisdictions: work with local teams to assess country-specific implementation, reporting requirements and practical implications.

Typical deliverables

• Public CbCR readiness review
• Public CbCR and master file consistency review
• TP and Pillar Two interaction assessment
• CbCR data quality and Pillar Two transitional safe harbour readiness review
• Amount B applicability assessment for distribution activities
• Jurisdictional regulatory tracker and compliance roadmap
• International developments impact memo
• Practical roadmap for data, documentation and reporting alignment

Typical triggers

• Upcoming Public CbCR publication deadline
• Need to assess consistency between CbCR data, master file and local files
• Pillar Two safe harbour or GloBE data readiness assessment
• Routine distribution structures potentially affected by Amount B
• Public tax transparency, ESG or governance questions
• Significant differences between jurisdictional profit allocation and operational footprint
• Need for a coordinated international response to new OECD, EU or Belgian developments