Over the past few years, transfer pricing has become an important topic for tax authorities around the world.
The number of publications issued by International Organizations such as the OECD, the European Union, the United Nations, the Pacific Association of Tax Administrators (PATA), the African Tax Administration Forum (AFTA), and others who have specialized in this area has continued to grow. The totality of these documents forms a global framework for the transfer pricing process, and the input of these organizations can be seen in transfer pricing legislation all over the world. It’s therefore worth monitoring the movements of these international bodies as tax authorities utilize their reports and introduce them into local tax laws.
In addition, there’s the OECD’s Model Tax Convention on Income and on Capital, which covers the issue of double taxation due to transfer pricing.
Over time, OECD Guidelines have become a reference point for tax administrations not only in OECD member countries, but in other
jurisdictions as well. The OECD’s work on transfer pricing is ongoing—in addition to the 2022 OECD Guidelines, detailed reports are often
issued, including “Guidance on the Transfer Pricing Implications of the Covid-19 Pandemic.”