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 […]

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.