In Brazil on 29th December 2022, draft legislation was published that updates current transfer pricing rules into a set of rules consistent with the OECD-guidelines.

EU member states reached agreement to implement at EU level the minimum taxation component, known as Pillar 2, of the OECD’s reform of international taxation.

On 16 May 2022 a Dutch transfer pricing case on interest rate benchmarking analysis was published. This district court case concerned the financing of a real estate investment and is of interest as it deals with interest rate benchmarking in some detail.

The Swiss Federal Tax Administration (SFTA) published two circulars on 27th and 28th January, updating the safe harbour interest rate guidance applicable for 2022.

The London Interbank Offered Rate (LIBOR) serves as the benchmark for an estimated US$370 trillion+ of financial transactions worldwide.

The COVID 19 pandemic is having an unprecedented effect on the world’s economy, global trade and supply chains and is disrupting the way in which MNEs conduct their business. The operational and the financial impacts of the pandemic will be felt by MNEs for the foreseeable future.

Question is supporting a number of Blockchain foundations to ensure they avoid potential issues arising from non arm’s length behavior that may create a substantial risk to the foundation and its stakeholders. Small issues can become big problems in terms of:

The OECD has today released their report “Transfer Pricing Guidance on Financial Transactions” (the original discussion draft was released in July 2018 as a continuation of the BEPS package of reports released in late 2015).

Denmark: No Transfer Pricing Adjustment for Factory Closure. On October 8, 2018 the National Tax Tribunal published a decision in a case (SKM2018.501LSR) on the transfer pricing aspects related to the closure of a factory in Denmark.