The OECD Council approved the contents of the 2025 Update to the OECD Model tax Convention on Income and Capital (“OECD MTC”) on 18 November 2025. The most significant update relates t0 permanent establishments in the context of cross border home office arrangements (see our newsletter). In addition to that, it also covers other cross-border […]
read more
Country-by-Country Reporting (CbCR) serves to provide information that enables tax authorities to conduct an informed risk assessment of transfer pricing. In May 2025, the OECD published a new overview of common errors made in preparing CbC reports. The document updated the summary from November 2019 with further common errors, reaching a total of 28. As […]
read more
Amount B of Pillar One offers a simplified transfer pricing approach for distribution entities of multinationals that meet certain criteria. In 2024, the OECD published the Amount B guidance, incorporated as an Annex to Chapter IV of the OECD Transfer Pricing Guidelines, and provided lists of covered and qualifying jurisdictions (follow the links to access […]
read more
The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD Transfer Pricing Guidelines) provide orientation when applying the arm’s length principle. On 20 January 2022, the OECD published a new version of these Transfer Pricing Guidelines. It is available in English and French on the OECD website. The OECD Transfer Pricing Guidelines 2022 replace […]
read more
