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The Transfer Pricing World in 2022
A Review
Following the general trend observed in recent times, the year 2022 experienced several developments in the transfer pricing world at different levels. These developments do not fully innovate in the international tax arena since they mostly derive from projects and behaviors whose initial stages date back to previous years. Nevertheless, they represent a shift to a new international tax environment, to which taxpayers and tax administrations will have to conform and comply with.
1. Introduction
A few trends can be observed that serve as proxies driving the ongoing progress of the transfer pricing world. First, it remains undeniable that despite loud calls against it, the application of transfer pricing rules embeds complexity. This is because the current business models accompanied by their commercial transactions only increase complexity, whereby a brick-and-mortar logic does not fit in anymore but needs to be set aside. For instance, the interplay of the detailed and comprehensive proposed revenue sourcing rules within the ambit of Amount A of the Pillar One project along with the Model Rules of the proposed Pillar Two project and the necessary coordination with the ALP indisputab...