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

Solving the UK's fiscal deficit requires an ‘ease of doing taxes’ framework driven by tax-as-code – not thousands of additional auditors
Despite the ongoing audit controversy, the firm’s tax and legal division saw revenue growth of 10.9%
Fresh from the UN negotiations in New York, Alex Cobham offers ITR readers a rare first-hand perspective on the future of international tax cooperation
Around 450 client-facing roles are due to be axed next week, it has been reported
The OECD may be making a mistake if a 2029 review is intended to outlast Trump in the hope of more favourable treatment from the US Democrats
Nexdigm has invested in Singapore-based infer360, a TP intelligence product designed by ex-PwC partners
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Americas Tax Awards
Despite initial hopes that the reporting obligation had been suspended, compliance challenges brought by Brazil’s indirect tax reform are very much a reality
As tax authorities embrace AI and governments weigh pillar two reforms, Latin America is developing a more connected and internationally focused tax agenda
Advisers with pre-existing corporation tax or self-assessment accounts must now register or risk enforcement action from HMRC
Gift this article