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The Transfer Pricing World in 2023
A Review
In alignment with the prevailing trends observed in recent years, the year 2023 witnessed notable developments in the transfer pricing landscape across different levels. While some of the legislative and guidance-based changes have reached final stages, their practical implications remain largely untested. Concurrently, other developments are still in incipient stages of development, indicating an ongoing evolution in the international tax landscape. These changes signal a pivotal moment in the evolution of transfer pricing practices, paving the way for a more nuanced and dynamic international tax environment.
1. Introduction
Converging to the experience of past years, the transfer pricing developments also stayed in focus during 2023 in different instances, thus dividing the attention with the much-commented Pillar Two developments. Yet for some at first sight not explicitly evident, the transfer pricing issues identified throughout the year corroborate the trends already observed in recent times and do not constitute a true breakthrough but rather a continuous development. This, however, does not mean that policymakers remained less ambitious.
At OECD level, for instance, the ongoin...