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 2026

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

If Trump continues to poke the world’s ‘middle powers’ with a stick, he shouldn’t be surprised when they retaliate
The Netherlands-based bank was described as an ‘exemplar of total transparency’; in other news, Kirkland & Ellis made a senior tax hire in Dallas
Zion Adeoye, a tax specialist, had been suspended from the African law firm since October over misconduct allegations
The deal establishes Ryan’s property tax presence in Scotland and expands its ability to serve clients with complex commercial property portfolios across the UK, the firm said
Trump announced he will cut tariffs after India agreed to stop buying Russian oil; in other news, more than 300 delegates gathered at the OECD to discuss VAT fraud prevention
Taxpayers should support the MAP process by sharing accurate information early on and maintaining open communication with the competent authorities, the OECD also said
The Fortune 150 energy multinational is among more than 12 companies participating in the initiative, which ‘helps tax teams put generative AI to work’
The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals
User-friendly digital tax filing systems, transformative AI deployment, and the continued proliferation of DSTs will define 2026, writes Ascoria’s Neil Kelley
Case workers are ‘still not great’ but are making fewer enquiries, making the right decision more often and are more open to calls, ITR has heard
Gift this article