Current Transfer Pricing Landscape – An Update

The 2013 OECD's Base Erosion and Profit Shifting (BEPS) initiative was aimed at combatting tax abusive and aggressive tax structures. The goal was to equip governments with domestic and international instruments, to ensure that profits will be taxed where economic activities generating these profits are performed and where value is created.

Below is an overview of the status of the transfer pricing related measures discussing which measures have been implemented to date and in particular how multinational entities (MNEs) may be impacted.

The transfer pricing related measures can be grouped into the following key areas:

• Updated OECD Transfer Pricing Guidelines;
• Transfer pricing documentation requirements; and