January, 24 2022
Recently, the OECD released the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
Take into consideration the globalization and the leading role of the multinational enterprises in the economy’ growth, there is a constant need to make sure that the economic activity undertaken is properly allocated to each jurisdiction and, subsequently, the profits are taxed in the right place. In this regard, transfer pricing rules are becoming an increasingly hot topic in the agenda of tax administrations and taxpayers.
In this regard, the OCDE published the 2022 edition with the main goal of reflects new modifications resulting from the OECD/G20 Base Erosion and Profit Shifting Project (BEPS), in particular on Actions 8-10, more precisely:
- Review of chapter II with reference to the situations to which the profit split method may apply, as well guidance on its adoption, in line with the guidelines published June, 2018 (Action 10, BEPS);
- Review of chapter VI to conform the guidance on hard-to-value intangibles, following the guidelines published June, 2018 (Action 10, BEPS); and
- Incorporation of a new chapter, with reference to specific guidance on financial transactions, following the guidelines published February, 2020 (Actions 4 and 8-10, BEPS).
For additional details, on this matter, please view more in here.
The information presented above is not intended to be an exhaustive analysis of all the changes to the current legal regime, but rather a selection of those that we believe to be the most relevant, and does not preclude consultation of our Company and / or legislation to which it refers.
For more information contact: Catarina Breia (+351 91 7575 832 or email@example.com) from our Tax Department.