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Multinational companies will have to abide by new Transfer Pricing Guidelines

Updated: Mar 15, 2023

The changes implemented in the OECD Transfer Pricing Guidelines 2022 require a review of the current regulations governing this matter in Panama. Find out what the changes are.


The changes implemented in the OECD Transfer Pricing Guidelines 2022 require a review of the current regulations governing this matter in Panama. Find out what the changes are.



On 20 January, the Organisation for Economic Co-operation and Development (OECD) published its new Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.



This new version of the Guidelines incorporated previous work developed by Working Group 6, which focuses on the taxation of multinational enterprises, in line with Actions 8, 9 and 10 "Ensure that transfer pricing outcomes are in line with value creation" of the OECD's Base Erosion and Profit Shifting Project (BEPS).

Among its new features is the expansion of the comments on the application of the Transactional Profit Sharing Method, specifying more precisely the cases in which this method would be the most appropriate: in cases of unique and valuable contributions by all parties involved in the transaction; where the activities carried out by the parties have a high degree of integration; and where relevant risks are shared. In addition to limiting its application, it also details the methodology to be followed and the importance of the existence or not of comparables in the market.


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