Transfer pricing is hot. The globalisation and also the rise of multinational enterprises make transfer pricing one of the most important themes on international taxes. Transfer pricing is moreover a key focus of the OECD’s Base Erosion & Profit Shifting (BEPS) project.
In the future, there will be far more emphasis on the substance and the economic behaviour underpinning the transaction in the context of the entire value chain, as opposed to the contractual analysis. The finalised guidelines, which provide for increased levels of TP documentation, will also result in unprecedented levels of transparency.
Overall, it is clear that the BEPS initiative is one of the biggest game-changers in international tax policy in living memory. The impact of the Action Plan will fundamentally change the way multinational organisations engage in international business, related-party dealings and business restructurings in the future.
SlideShare Presentation: Transfer Pricing and BEPS