OECD recognises the need for change in transfer pricing

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

OECD recognises the need for change in transfer pricing

The need to realign international tax and transfer pricing policy, to better integrate developing countries, has never been more apparent at the International Tax Review Global Transfer Pricing Forum.

Speakers including the OECD, the Canada Revenue Authority, the tax director for LVMH, and advisers from Baker & McKenzie and KPMG, focused on the role developing countries are playing in international business and tax policy, for their panel on changes and trends in global transfer pricing.

Caroline Silberztein, a partner at Baker & McKenzie and an ex-OECD official, said it was easier when people had never heard of transfer pricing because now it is synonymous with tax avoidance, which is not the correct conclusion.

The OECD is an obvious player in international tax policy and still holds the majority of influence. Marlies de Ruiter, head of the organisation ’s tax treaty, transfer pricing and financial transactions division, said the OECD is recognising the issues that drive transfer pricing debate: “Implementation can be subjective, however.”

De Ruiter said the purpose of the OECD’s inclusive meetings, which welcome non-members, is to promote dialogue between countries.

However “sharing thoughts to overcome problems doesn’t mean both parties always agree”.

The UN became an observer of the OECD’s Committee on Fiscal Affairs in June this year. “We are moving closer together,” said de Ruiter, “but we are not always on the same page.”

She refers to the debate, by OECD critics, that the OECD is an exclusive club that does not necessarily represent the interests of non-members.

On the development of a transfer pricing manual for developing countries, de Ruiter said she is happy that the UN states the manual is an interpretation of the OECD guidelines “but I am concerned if they are using the same standard and different words. People will interpret them differently”.

more across site & shared bottom lb ros

More from across our site

The US president also unveiled a new 50% levy on copper imports; in other news, a UK wealth tax proposal has been criticised by the Institute for Fiscal Studies
Wim Wuyts, who had been head of the specialist tax network since 2017, is moving on to a new role with WTS’s Belgian member firm
MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process
The Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities
Grant Thornton’s Austria tax head likens his practice to an escape room, shares his football coaching ambitions, and explains why tax is cool
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 Asia-Pacific Tax Awards
The fates of pillars one and two hang in the balance after the US successfully threw its weight around in G7 and Canadian negotiations
Rafael Tena tells ITR about the ‘crazy’ Mexican market, ditching the hourly rate, and refusing to grow his fledgling firm in an ‘unstructured way’
It should be easy for advisers to be transparent about costs, Brown Rudnick partner Matthew Sharp said in response to exclusive ITR in-house data
Gift this article