For the majority of multinational businesses transfer pricing represents the largest single tax risk. In recent years there has been a raft of changes which will affect how multinationals price internal transactions and also how they need to document their arrangements.
Many of the changes set out in the OECD's new Transfer Pricing guidelines have now been adopted into local rules, but other changes are still being rolled out. These include new guidance on the use of profit splits and the attribution of profits to permanent establishments.
The OECD's new documentation requirements including a master file, local files and (where the size thresholds are met) Country by Country Reports are now being implemented by many multinationals but the timings for implementation vary considerably around the world.
Join our next webinar on 10 October to hear from BDO International advisers and be guided through the latest developments to ensure you stay on top of your transfer pricing requirements.