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 […]
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 […]
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 […]
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 […]
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 […]
