The new OECD transfer pricing guidelines on business restructuring: a deeper dive – MNE Tax

by Ajit Jain The OECDs new transfer pricing approach to business restructuring, as described in Chapter IX of 2017 OECD transfer pricing guidelines, has changed radically from prior versions. These new transfer pricing guidelines, released on July 10, echo important changes made in 2015 OECD/G20 base erosion and profit shifting (BEPS) project regarding how to…