In May and July 2025, the OECD released updated Transfer Pricing Country Profiles, expanding coverage to over 78 jurisdictions. These updates mark a significant step forward in transparency, offering multinational enterprises (MNEs) a clearer view of how different countries implement the OECD Transfer Pricing Guidelines. For the first time, the profiles incorporate information on hard-to-value […]
The OECD’s Pillar Two framework is a landmark in international taxation. By setting a floor for corporate taxation worldwide, it seeks to balance fairness, efficiency, and competitiveness in the global economy. For businesses, the message is clear: the era of aggressive profit shifting is ending, and proactive compliance will be essential. Primary Link | […]
On 20 January 2022, the OECD released a fully updated version of its Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. This edition consolidates years of work following the Base Erosion and Profit Shifting (BEPS) project and provides greater clarity on how transfer pricing (TP) principles should be applied in practice. The updates are […]
October Statement As mentioned in past posts, the OECD created Two Pillar in order to address tax challenges arising from the digitalization of the economy. In October 2021, the OECD published a statement indicating that the Inclusive Framework has agreed on a two-pillar solution. What does this mean? Pillar 1 The […]
The IRS concluded in aChief Counsel Advice Memorandum, how a branded prescription drug (BPD) fee is determing. EY analyzes this topic in a deep, clear way. Learn more The five-factor test The CCA analysis began by defining gross income, as all income from whatever source derived. The IRS described circumstances under which a taxpayer generally […]
Earlier this month, the OECD updated the TP country profiles for financial transactions and permanent establishments. According to the OECD release, this update reflects the current TP legislation and practices of 20 jurisdictions. These updated profiles also contain new information on countries’ legislation and practices regarding the transfer pricing treatment of financial transactions and the […]
Since this is my personal blog, I would like to share some of my personal favorite podcasts and/or episodes that have inspired me. I’ll try to keep this section updated. Ursula Burns, former CEO, Xerox: 9to5ish with theskimm Why I’m done trying to be “man enough” | Justin Baldoni: TED Talks Daily An MVP for […]
In a world where Digitalisation is growing second-by-second, Digital Economy has been a challenge for tax authorities around the world. The first Report in regards to this topic that the OECD released was in 2015, the Action 1 Final Report. One of the conclusions of this report was to start introducing key features of […]
Some months ago, I started studying Data Analytics, which opened my mind to the amount of information and data that people consumed every day. Transfer Pricing has updated its digitalization but, to me, there’s a long way to go in order to have standardization in the way the firms collect their information, the way […]
COVID-19 has impacted the world in different ways. Of course, Transfer Pricing isn’t the exception. Some jurisdictions have easy up on certain compliance-related obligations. “These include postponing deadlines for transfer pricing declarations, forms and filings, including Country-by-Country (CbC) notification and CbC Report filing deadlines.” EY Transfer Pricing Tracker provides related and updated information.
