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BEPS 2.0 state of play - Developments summary

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Last updated 5 March 2024

Global Transfer Pricing Review

Global Transfer Pricing Review

Transfer pricing documentation summaries by jurisdiction

TaxNewsFlash

TaxNewsFlash

Latest tax developments being reported by KPMG member firms from around the globe

February 2024

29 Feb - OECD: Report to G20 Finance Ministers and Central Bank Governors, updates on developments in international tax reforms

28 Feb - Greece: Proposed legislation implementing Pillar Two global minimum tax

28 Feb - Malta: Legislation implementing Pillar Two global minimum tax

28 Feb - South Africa: Draft legislation implementing Pillar Two global minimum tax

26 Feb - OECD: Comments on public consultation on toolkit to support developing countries in addressing BEPS risks when pricing minerals (lithium)

23 Feb - Slovakia: Legislation implementing Pillar Two global minimum tax passed by Parliament

21 Feb - KPMG report: Overview and initial observations on Pillar One – Amount B

21 Feb - EU: Updates to list of non-cooperative jurisdictions

20 Feb - Singapore: Tax measures in budget 2024 include Pillar Two global minimum tax rules

19 Feb - OECD: Report on Amount B under Pillar One

15 Feb - United States: Treasury statement regarding extended agreement on digital services taxes imposed by Austria, France, Italy, Spain, United Kingdom

13 Feb - Greece: Guidance on new reporting obligations for digital platform operators (DAC7)

9 Feb - Belgium: Provisions transposing DAC6 mandatory disclosure rules annulled (Constitutional Court decisions)

9 Feb - Belgium: Public country-by-country reporting implemented

9 Feb - EU: Certain member states extend DAC7 reporting deadlines

9 Feb - EU: Formal notices to nine member states on failure to transpose minimum tax directive

9 Feb - Spain: Draft legislation implementing Pillar Two global minimum tax

9 Feb - Netherlands: FAQs on reporting obligations of digital platform operators (DAC7)

7 Feb - Netherlands: EC approval of COVID-19 related State aid annulled (CJEU General Court judgment)

6 Feb - Australia: Senate Committee report on interest limitation / thin capitalisation rules bill

5 Feb - Japan: Additional guidance on income inclusion rule

January 2024

30 Jan - Germany: Final guidance on CFC rules, other tax developments

30 Jan - Latvia: Draft legislation implementing Pillar Two global minimum tax

30 Jan - Sweden: European Commission opens State aid investigation into non-food biogas and bio-propane tax exemption schemes

30 Jan - EU: Public country-by-country reporting implementation summary

29 Jan - Australia: Guide on hybrid mismatch rules; new case studies on offshore tax evasion

29 Jan - UK: Government response to consultations on proposed changes to transfer pricing and international tax rules

29 Jan - OECD: Aggregated ICAP statistics

22 Jan - OECD: Comments on public consultation on model treaty commentary on permanent establishments as applied to extractible natural resources

19 Jan - Belgium: Anti-abuse rule applied to deny withholding tax exemption under EU Parent-Subsidiary Directive (Supreme Court decision) 

19 Jan - Denmark: Proposed updates to list of jurisdictions subject to defensive tax measures

19 Jan - EU: Challenge to EU global minimum tax directive dismissed (EU General Court judgment)

19 Jan - Germany: Interest deduction limitation rules aligned with ATAD

19 Jan - Italy: Procedure for obtaining hybrid mismatch penalty protection

18 Jan - Italy: Pillar Two global minimum tax rules implemented

17 Jan - Czech Republic: Legislation introducing top-up tax, implementing EU directive on global minimum tax, now effective

17 Jan - EU: Pillar Two global minimum tax implementation summary

16 Jan - Belgium: Lower house of Parliament adopts draft law implementing public country-by-country reporting

16 Jan - Romania: Law implementing Pillar Two global minimum tax

16 Jan - UK: Updates on Pillar Two, including draft HMRC guidance on proposed rules

11 Jan - France: Tax-related provisions in finance law for 2024, including Pillar Two rules and transfer pricing documentation changes

10 Jan - Korea: Amendments to Pillar Two rules enacted

10 Jan - United States: Certain challenges to Maryland digital advertising tax barred, but constitutional challenge may proceed

5 Jan - India: Guidelines for withholding tax on e-commerce transactions

2 Jan - Hong Kong: Consultation paper on implementation of Pillar Two global minimum tax

2 Jan - KPMG report: Pillar Two rules and the asset management industry

2023 Articles

December 2023

29 Dec - Zimbabwe: Legislation implementing Pillar Two global minimum tax enacted

22 Dec - EU: EC publishes FAQs on interpretation and transposition of EU global minimum tax

22 Dec - Switzerland: Law implementing Pillar Two minimum tax rule enacted

20 Dec - KPMG report: New administrative guidance on Pillar Two rules, initial observations and analysis

20 Dec - EU: Pillar Two global minimum tax implementation summary

20 Dec - Luxembourg: Law implementing Pillar Two global minimum tax enacted

20 Dec - Netherlands: 2024 Tax Plan package and law implementing Pillar Two global minimum tax enacted

19 Dec - Ireland: Legislation implementing Pillar Two signed into law

19 Dec - Hong Kong: Update on implementation of Pillar Two global minimum tax

18 Dec - OECD: Further administrative guidance on Pillar Two rules; statement on timeline of Pillar One multilateral convention

15 Dec - Belgium: Pillar Two global minimum tax rules adopted by Parliament

15 Dec - KPMG report: Transfer pricing implications of Pillar Two minimum tax rules

14 Dec - Luxembourg: European Commission erred in finding grant of State aid based on OECD Transfer Pricing Guidelines (CJEU judgment)

14 Dec - Moldova: Public country-by-country reporting implemented

13 Dec - OECD: Exchange of information on tax rulings under BEPS Action 5

12 Dec - Belgium: Draft law proposes new stricter CFC rules

8 Dec - Australia: Judgment on embedded royalties and application of diverted profits tax (DPT) publicly released (Federal Court decision)

8 Dec - Croatia: Consultation on draft legislation implementing Pillar Two global minimum tax

8 Dec - EU: ECOFIN report addressing “Unshell” and FASTER directives

8 Dec - Hungary: Legislation implementing Pillar Two global minimum tax enacted

8 Dec - Moldova: Draft law implementing country-by-country reporting

8 Dec - Thailand: Required reporting by digital platform operators

8 Dec - UK: Finance Bill 2024, including amendments to Pillar Two minimum tax rules

7 Dec - Italy: Guidance on new reporting obligations for digital platform operators (DAC7)

6 Dec - Luxembourg: Amended draft law implementing Pillar Two global minimum tax

5 Dec - KPMG report: OECD official provides update on expected transfer pricing guidance

4 Dec - Canada: First reading of second 2023 federal budget bill includes EIFEL, hybrid mismatch, and DST rules

1 Dec - Australia: Tax treaty with Portugal signed

1 Dec - Australia: Taxpayer liable for withholding tax on embedded royalties, application of DPT (Federal Court decision)

November 2023

29 Nov - Australia: Amendments to new interest limitation / thin capitalisation rules tabled in Senate

29 Nov - Vietnam: Resolution adopting Pillar Two global minimum tax

27 Nov - UK: Update on consultation on proposed changes to transfer pricing and permanent establishment rules

24 Nov - Austria: Updated draft legislation implementing Pillar Two global minimum tax

24 Nov - Norway: Amended draft legislation implementing Pillar Two global minimum tax

24 Nov - Slovenia: Updated draft legislation implementing Pillar Two global minimum tax

21 Nov - KPMG report: Pillar Two implications for “U.S. sandwich structures”

16 Nov - Bermuda: Third public consultation related to proposed corporate income tax

16 Nov - OECD: Public consultation on model treaty commentary on permanent establishments as applied to extractible natural resources

14 Nov - Germany: Law implementing Pillar Two global minimum tax passed by lower house of Parliament

14 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2022

13 Nov - Barbados: Proposed rules to implement Pillar Two global minimum tax

10 Nov - Liechtenstein: Law implementing Pillar Two global minimum tax adopted by Parliament

9 Nov - EU: Member states approve statements of EU Council and European Commission reconfirming support for Pillar One and Pillar Two

9 Nov - Ireland: Judgment of General Court regarding tax rulings issued to multinational group must be set aside (CJEU Advocate General opinion)

9 Nov - Belgium: Referral to CJEU for failing to correctly transpose ATAD CFC rules

9 Nov - Cyprus: Consent to Pillar Two global minimum tax rules

9 Nov - Estonia: Legislative proposal implementing Pillar Two global minimum tax rules

9 Nov - Greece: Public consultation on implementation of public country-by-country reporting

8 Nov - Malaysia: Finance Bill (No. 2) 2023 includes proposed Pillar Two rules

6 Nov - OECD: Public consultation on additional toolkit to support developing countries in addressing BEPS risks when pricing minerals

6 Nov - Sweden: Updated draft legislation implementing Pillar Two global minimum tax

October 2023

31 Oct - Australia: KPMG comments on consultation on proposed amendments to new interest limitation / thin capitalisation rules

31 Oct - Malta: Tax measures in budget 2024, including deferral of implementation of Pillar Two global minimum tax

31 Oct - UAE: Transfer pricing guide issued

27 Oct - Lithuania: Draft legislation implementing Pillar Two global minimum tax

27 Oct - KPMG report: U.S. transfer pricing and international tax year-end considerations

25 Oct - Australia: Extended due date for filing country-by-country (CbC) reports, Master and Local files

24 Oct - Belgium: FAQ on new obligations of digital platform operators (DAC7)

23 Oct - Hungary: Proposed legislation implementing Pillar Two global minimum tax

23 Oct - Romania: Proposed legislation implementing Pillar Two global minimum tax

20 Oct - Ireland: Tax proposals in Finance bill 2023 include implementation of Pillar Two global minimum tax

18 Oct - Australia: Consultation on proposed amendments to new interest limitation / thin capitalisation rules

18 Oct - France: Tax measures in 2024 draft finance law include Pillar Two implementation and transfer pricing documentation changes

17 Oct - KPMG report: Multilateral conventions on Amount A of Pillar One and Pillar Two subject to tax rule, initial observations and analysis

17 Oct - Belgium: Public country-by-country reporting draft law approved

17 Oct - EU: Updates to list of non-cooperative jurisdictions

16 Oct - UK: Further analysis of Pillar Two global minimum tax rules in updated Finance Bill 2023 draft legislation

12 Oct - Cyprus: Status of bilateral Competent Authority Arrangement for exchange of CbC reports with United States

11 Oct - OECD: Multilateral convention to implement Amount A of Pillar One; implementation handbook for Pillar Two global minimum tax

11 Oct - United States: Treasury request for public input on OECD multilateral convention to implement Amount A of Pillar One

6 Oct - Bermuda: Second public consultation related to proposed corporate income tax

6 Oct - Cyprus: Public consultation on draft legislation implementing Pillar Two global minimum tax

5 Oct - Bulgaria: Public consultation on draft legislation implementing Pillar Two global minimum tax

5 Oct - France: Draft legislation implementing Pillar Two global minimum tax

5 Oct - Latvia: Public country-by-country reporting legislation approved

5 Oct - Austria: Updated DAC6 guidance

5 Oct - Austria: Draft legislation implementing Pillar Two global minimum tax

4 Oct - Denmark: Updated draft legislation implementing Pillar Two global minimum tax

3 Oct - OECD: Multilateral convention to facilitate implementation of Pillar Two subject to tax rule

3 Oct - Japan: Guidance on income inclusion rule

2 Oct - Costa Rica: Legislative Assembly overrides veto of bill on taxation of passive income

August 2023

31 Aug - New Zealand: Bill to implement digital services tax

30 Aug - Portugal: Public country-by-country reporting legislation approved

29 Aug - Finland: Public consultation on implementation of Pillar Two global minimum tax rules

29 Aug - Netherlands: Draft legislation implementing public country-by-country reporting

29 Aug - United Kingdom: Policy paper on reporting obligations for digital platform operators (DAC7)

25 Aug - KPMG report: Potential U.S. tax implications of proposed Bermuda corporate income tax

23 Aug - Canada: Details of draft revised DST rules

23 Aug - Tunisia: Instrument of ratification of MLI deposited with OECD

21 Aug - Korea: Proposed amendments to transfer pricing and Pillar Two rules

15 Aug - Australia: Targeted consultation on implementation of Pillar Two global minimum tax rules

14 Aug - Canada: Draft legislation includes Pillar Two rules and revised DST and EIFEL rules

10 Aug - Korea: Tax reform proposal for 2023, changes to Pillar Two and transfer pricing documentation rules

10 Aug - Luxembourg: Draft law implementing Pillar Two global minimum tax

9 Aug - Bermuda: Implementation of corporate income tax within scope of Pillar Two global minimum tax rules

4 Aug - Croatia: Implementation of public country-by-country reporting

4 Aug - EU: Formal notice to 14 member states of failure to implement public country-by-country reporting

4 Aug - EU: Reasoned opinion to six member states on failure to fully transpose DAC7

4 Aug - Hungary: Formal notice of failure to align corporate income tax rules with ATAD

4 Aug - Ireland: Feedback statement on implementation of Pillar Two global minimum tax

4 Aug - Luxembourg: Referral to CJEU by European Commission for failure to correctly transpose ATAD interest limitation rules

3 Aug - KPMG report: Amount B and tax certainty

2 Aug - Germany: Draft guidance on CFC rules

2 Aug - Germany: Draft guidance on hybrid mismatch rules

July 2023

31 Jul - EU: Public country-by-country reporting implementation summary

25 Jul - KPMG report: New guidance on Pillar Two rules, initial observations and analysis

25 Jul - KPMG report: Public consultation on Amount B under Pillar One, initial observations

25 Jul - KPMG report: OECD’s effort to simplify transfer pricing

20 Jul - KPMG report: Latest Pillar Two guidance provides some relief for U.S. multinationals, but concerns remain

17 Jul - OECD: Report on BEPS 2.0, including new guidance on Pillar Two rules

17 Jul - OECD: Public consultation document on Amount B under Pillar One following outcome statement on BEPS 2.0

14 Jul - Gibraltar: 2023 budget includes consultation on implementation of Pillar Two global minimum tax, stamp tax changes

13 Jul - Thailand: Guidance for taxpayers within scope of Pillar Two global minimum tax rules

12 Jul - OECD: Outcome statement on BEPS 2.0

12 Jul - EU: European Commission progress report on Pillar One

12 Jul - Germany: Draft bill implementing Pillar Two global minimum tax

12 Jul - Latvia: Updated list of non-cooperative jurisdictions

12 Jul - Liechtenstein: Consultation on implementation of public country-by-country reporting

12 Jul - Malta: Guidance on DAC7

12 Jul - Netherlands: Proposed amendments to tax ruling policy

12 Jul - UK: HMRC removes requirement for UK companies to make annual country-by-country reporting notification

11 Jul - Poland: Mobile application for e-invoicing; consultation on schemas for digital platform operators (DAC7)

7 Jul - Luxembourg: Updated FAQ on mandatory disclosure rules (DAC6)

5 Jul - Australia: Legislation proposing changes to interest limitation rules introduced in Parliament

June 2023

29 Jun - Romania: Amendments to public country-by-country reporting rules

28 Jun - Germany: Updated transfer pricing guidelines; U.S. agreement on automatic exchange of country-by-country reporting

28 Jun - France: Implementation of public country-by-country reporting

28 Jun - Lithuania: Country-by-country reporting directive transposed into domestic law

28 Jun - Luxembourg: Guidance on reverse hybrid rules

28 Jun - OECD: Updated guidelines for multinational enterprises, final cryptoasset reporting framework rules

28 Jun - EU: European Commission guidance on foreign subsidies regulation

27 Jun - Denmark: Public consultation on draft bill to implement Pillar Two global minimum tax

27 Jun - OECD: Tax transparency in Latin America 2023

26 Jun - UK: Draft guidance on Pillar Two global minimum tax rules published, comments requested

26 Jun - UK: Spring Finance Bill 2023, including Pillar Two global minimum tax rules, substantively enacted

22 Jun - Germany: Legislation to implement country-by-country reporting directive

21 Jun - United States: JCT analysis of possible effects of Pillar Two global minimum tax adoption

21 Jun - OECD: Continued progress on harmful tax practices

21 Jun - Switzerland: Implementation of Pillar Two minimum tax approved by public vote

16 Jun - Norway: Draft legislation implementing Pillar Two minimum tax

14 Jun - Denmark: Public country-by-country reporting legislation passed

13 Jun - Czech Republic: Proposed legislation introducing top-up tax, implementing EU directive on global minimum tax

12 Jun - Hong Kong: Update on profits tax, BEPS 2.0, and e-filing

8 Jun - Liechtenstein: Consultation draft for implementation of Pillar Two global minimum tax

8 Jun - Luxembourg: European Commission erred in finding grant of State aid based on OECD Transfer Pricing Guidelines (CJEU Advocate General opinion)

6 Jun - Germany: Interim findings and outcomes from mandatory disclosure rules (DAC6) reporting

6 Jun - Luxembourg: Draft law implementing DAC7

6 Jun - Switzerland: Consultation on draft law implementing Pillar Two global minimum tax

5 Jun - Netherlands: Bill implementing Pillar Two presented to Lower House of Parliament

2022 Articles

December 2022

22 Dec - Latvia: New reporting obligations for digital platform operators (DAC7)

22 Dec - Netherlands: 2023 Tax Plan adopted by upper house of Parliament, including DAC7, windfall profits tax on fossil sector

22 Dec - Spain: Guidance on online “intermediation” subject to digital services tax

22 Dec - KPMG report: Public consultation document under Pillar One on draft multilateral convention provisions on DSTs

21 Dec - KPMG report: Pillar Two implementation package, initial observations and analysis

20 Dec - OECD: Public consultation documents on withdrawal of DSTs under Pillar One, implementation under Pillar Two

19 Dec - Colombia: Tax reform measures include 15% minimum tax, surcharges, digital services tax

16 Dec - Belgium: New obligations of digital platform operators (DAC7)

16 Dec - Luxembourg: 2023 budget law passed by Parliament includes reverse hybrid rule changes

16 Dec - Switzerland: Parliament approves constitutional amendment to implement Pillar Two global minimum tax

16 Dec - EU: Council adopts EU minimum tax directive

15 Dec - Mexico: Limitation on deductibility of net interest held valid (court decision)

14 Dec - OECD: Exchange of information on tax rulings under BEPS Action 5

13 Dec - EU: Member states in the EU reach agreement to implement Pillar Two (updated)

9 Dec - KPMG report: Public consultation on Amount B under Pillar One, initial observations and analysis

9 Dec - Slovakia: Public country-by-country reporting implemented

9 Dec - UK: Report of national audit office on operation and implementation of digital services tax

8 Dec - OECD: Public consultation document on Amount B under Pillar One

7 Dec - Estonia: Recent tax-related developments, including reporting obligations for digital platform operators (DAC7)

6 Dec - EU: Minimum tax directive proposal removed from ECOFIN meeting agenda

6 Dec - Kenya: Country-by-country reporting multilateral competent authority agreement signed

6 Dec - Romania: Public country-by-country reporting implemented

1 Dec - Finland: Clarifications on DAC7 reporting obligations

1 Dec - Spain: Reverse hybrid mismatch rules introduced

1 Dec - United Nations: Resolution to develop new international tax cooperation framework  

November 2022

30 Nov - Germany: Law on DAC7, submitting transfer pricing documentation in tax audits, adopted by lower house of Parliament

30 Nov - Poland: Legislation implementing “public” country-by-country reporting directive announced

29 Nov - KPMG report: Key takeaways from the OECD’s 2021 mutual agreement procedure (MAP) statistics

22 Nov - OECD: Mutual agreement procedure (MAP) statistics for 2021

22 Nov - Poland: Ratification of treaty with Georgia; MCAA for automatic information exchange under digital platform reporting rules signed

22 Nov - EU: Public country-by-country reporting implementation summary

17 Nov - UK: Autumn statement includes transfer pricing documentation changes, update on implementation of Pillar Two, increases in corporation tax and DPT rates

17 Nov - Argentina: Update on ratification of MLI

16 Nov - Denmark: DAC7 guidance

16 Nov - OECD: Comments on progress report on administration and tax certainty aspects of Amount A of Pillar One

11 Nov - KPMG report: Comments on progress report on administration and tax certainty aspects of Amount A of Pillar One

10 Nov - OECD: Jurisdictions sign MCAA for automatic information exchange under digital platform reporting rules, CRS disclosure rules

10 Nov - United States: Corporate Alternative Minimum Tax considerations and FAQs

9 Nov - Poland: Draft legislation guidelines of reporting obligations for digital platform operators (DAC7)

8 Nov - Luxembourg: Finding of illegal State aid involving application of arm’s length principle set aside (CJEU judgment)

4 Nov - Netherlands: Updated policy statement on hybrid mismatches, deduction allowed in cost-plus situations

3 Nov - Austria: Inflation relief-related tax measures, DAC7 implementation, guidance on crypto taxation, updated VAT guidelines, other tax developments

3 Nov - FinlandDraft legislation to implement DAC7

3 Nov - Germany: Draft legislation to implement public country-by-country reporting; update on Pillar Two implementation

3 Nov - Hungary: Draft legislation to implement public country-by-country reporting

October 2022

27 Oct - Australia: Public country-by-country (CbC) reporting proposed in 2022-2023 federal budget

25 Oct - Netherlands: Consultation on implementation of Pillar Two rules

20 Oct - Germany: Penalties for failure to comply with the obligation to keep or provide transfer pricing documentation compatible with EU law (CJEU judgment)

20 Oct - OECD: Report to G20 Finance Ministers and Central Bank Governors, updates on developments in international tax reforms

20 Oct - Romania: Bill implementing public country-by-country (CbC) reporting directive

19 Oct - KPMG report: Initial observations of OECD report on tax incentives and the global minimum tax

18 Oct - Mexico: Update on ratification of MLI

17 Oct - KPMG report: Comments in response to EC public consultation on the SAFE initiative

17 Oct - South Africa: MLI to enter into force 1 January 2023

14 Oct - OECD: Updated guidance on implementation of country-by-country reporting

14 Oct - Colombia: Tax proposals in draft legislation include 15% minimum tax, surcharges on certain sectors, digital services tax

14 Oct - Australia: New income tax treaty with Iceland signed, incorporating BEPS recommendations

13 Oct - Australia: Consultation paper on BEPS 2.0

13 Oct - Belgium: Tax proposals in budget 2023-2024 include 15% minimum tax

11 Oct - Hong Kong: Proposed incorporation of MLI into domestic law

7 Oct - Malaysia: Tax proposals in budget for 2023, including domestic minimum top-up tax

6 Oct - OECD: Report on tax incentives and the global minimum tax

6 Oct - OECD: Progress report on administration and tax certainty aspects of Amount A of Pillar One; public consultation

6 Oct - EU: Report on EU Parliament meeting with European Commissioner; discussion of solidarity contribution on surplus profits in fossil sector, minimum tax directive

May 2022

27 May - OECD: Tax certainty aspects of Amount A under Pillar One; public consultation

25 May - OECD: Comments on regulated financial services exclusion under Amount A of Pillar One

24 May - EU: Status regarding proposal for EU minimum tax directive

23 May - Australia: Labor party wins 2022 election, tax policies include public country-by-country (CbC) reporting

20 May - KPMG report: Comments on regulated financial services exclusion under Amount A of Pillar One

17 May - Luxembourg: FAQ on mandatory disclosure rules (DAC6)

16 May - KPMG report: Public consultation meeting on implementation framework of global minimum tax

10 May - Poland: Mandatory disclosure requirement deadlines for domestic arrangements remain extended

6 May - Malta: FAQs on mandatory disclosure rules (DAC6)

6 May - Netherlands: Considerations for companies in scope of Pillar Two rules

6 May - New Zealand: Consultation on implementation of Pillar Two rules

6 May - OECD: Regulated financial services exclusion under Amount A of Pillar One; public consultation

5 May - KPMG report: BEPS 2.0 implementation considerations for Mexico

5 May - Canada: Draft hybrid mismatch legislation

4 May - Nigeria: Summary of tax transparency reporting developments

4 May - OECD: Tax transparency in Latin America 2022

3 May - OECD: Comments on extractives exclusion under Amount A of Pillar One

3 May - KPMG report: Comments on extractives exclusion under Amount A of Pillar One

3 May - Switzerland: Tax transparency reporting statistics and global minimum tax update

2 May - UK: Additional compliance requirements under hybrid mismatch rules

2 May - UK: Transfer pricing statistics (FY 2021)

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