Open Arm's Length

A Transfer Pricing Blog by Maria Paula

Transfer pricing country profiles

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 […]

The Challenges of Digital Economy

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 […]

TP Tendencies

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 […]

How COVID-19 has change TP approach

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.

The future of Transfer Pricing

The future of Transfer Pricing As mention in other posts, the pandemic has marked our life in different ways.   The global economy was shaken, rattled, and rolled in 2020. Even though 2021 looks and feels brighter than the last year, it’s too premature to say that we’ll be back to what was previously considered […]

Tax relief for business

  During a catastrophic year for businesses because of the pandemic, some jurisdictions provided relief that included delayed filing deadlines, deferred collection of some taxes, and a pause in audit and litigation activity, as well as a stimulus.    However, the economy was extremely hurt, with big fiscal deficits, unemployment, and tax challenges. So, what […]

Open Arms Length 2.0 Is Live!

I would like to thank everyone for their support in this project. I’m truly passionate about Transfer Pricing and hope I can inspire other like-minded individuals to join the field and participate in the exciting conversations. Welcome to my newly redesigned newsletter website! It’s a new look and feel, while delivering the same level of […]