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Taxation and Customs Union

Joint Transfer Pricing Forum

A forum that assisted and advised the European Commission on transfer pricing tax matters

Joint Transfer Pricing Forum

The Joint Transfer Pricing Forum (JTPF) was an informal body set up to assist and advise the European Commission on transfer pricing tax matters. It has since been discontinued.

Background

In the EU, transfer pricing is not harmonised through legislative acts. The JTPF was thus set up in 2002 to support the European Commission by proposing pragmatic, non-legislative solutions to practical problems posed by transfer pricing practices in the EU. 

The overarching aim of its work was to address diverging approaches at the national level that result in excessive or overly complex rules, thereby creating significant costs and administrative burdens for both tax administrations and taxpayers. 

The JTPF was involved in a series of EU initiatives to create a common framework for coordinating domestic transfer pricing rules. This includes guidance and recommendations on all steps of the TP process, from determination and documentation to auditing and dispute resolution. 

Today, all EU Member States have adopted the OECD transfer pricing standard: the Arm’s Length Principle or equivalent measures. 

Mandate

The JTPF works within the framework of the OECD Transfer Pricing Guidelines and operates by consensus. Its work is divided into 2 main areas: 

  • the Arbitration Convention (AC) - a specific dispute resolution mechanism for transfer pricing cases 
  • other transfer pricing issues identified by JTPF and included in its work programme 

Members

The JTPF consisted of one representative from each EU Member State's tax administration and 18 non-governmental organisation members. It was chaired by an independent chairperson. Representatives from EU candidate countries (Albania, Republic of North Macedonia, Iceland, Montenegro, Serbia and Turkey) and OECD members may be invited as observers. 

Publications

Publications and reports
Member States’ Transfer Pricing Profiles: 
AT BE BG HR CY CZ DK EE FI FR DE GR HU IE IT LV LT LU MT NL PL PT RO SK SI ES SE UK 

Statistics on Mutual Agreement Procedures (MAPs) and Advance Pricing Agreements (APAs) 

For pre-2017 statistics, please consult the Meeting Archive section below. 

Report on the application of the profit split method within the EU 
Report on a coordinated approach to transfer pricing controls within the EU 
Report on the use of economic valuation techniques in transfer pricing 
Report on the use of comparables in the EU 
Study on comparable data used for transfer pricing in the EU 
Study on the application of economic valuation techniques for determining transfer prices of cross-border transactions between members of multinational enterprise groups in the EU 
Report on Compensating Adjustments 
Report on Transfer Pricing Risk Management 
Report on Secondary Adjustments 
Report on Cost Contribution Arrangements on Services not creating Intangible Property (IP) 

Report on Small and Medium Enterprises (SMEs) and transfer pricing 

SMEs and transfer pricing in each Member State: AT BE BG HR CY CZ DK EE FI FR DE GR HU IE IT LV LT LU MT NL PL PT RO SK SI ES SE UK 

Potential approaches to non-EU triangular cases 
Guidelines on low-value-adding intra-group services 
Guidelines for Advance Pricing Agreements (APAs) in the EU 
Code of conduct on transfer pricing documentation for associated enterprises in the EU 
Code of conduct for the effective implementation of the Arbitration Convention 

Meeting archive 

2002: 1 / 2 2003: 3 / 4 / 5 / 6 2004: 7 / 8 / 9 / 10 2005: 11 / 12 / 13 / 14 2006: 15 / 16 / 17 / 18 2007: 19 / 20 2008: 21 / 22 / 23 2009: 24 / 25 / 26 2010: 27 / 28 / 29 2011: 30 / 31 / 32 2012: 33 / 34 / 35 2013: 36 / 37 / 38 2014: 39 / 40 / 41 2015: 42 / 43 / 44 2016: 45 / 46 / 47 2017: 48 / 49 2018: 50 / 51 / 52 2019: 53