Domestic Transfer Pricing Laws versus Global Standards: Harmonizing in Dissonance within the G20 and Beyond
Journal
Country
Brazil; International; OECD
Published Date
Issue
Bulletin for International Taxation 2024 (Volume 78), No. 11
Document
The significance of changes to the OECD Transfer Pricing Guidelines after 2017 cannot be understated. Implementation of new activity-based concepts of value creation varies across OECD members, G20 countries and beyond, increasing risks of double-taxation. This requires wider adoption of MAP arbitration, within and beyond the OECD world.