Learning Center

Multinational enterprises (MNEs) account for nearly 80% of world trade. Many countries depend on tax revenues from MNEs, which has led to tax authorities around the world frequently and aggressively targeting the appropriateness of transfer prices. As a result, transfer pricing, one of the main technical topics within global supply chain management, is now even higher on the agenda for CFO teams of MNEs. Since 1979, the Organization for Economic Co-operation and Development (OECD) has set international standards in transfer pricing. In January 2022, the OECD published the updated Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (Guidelines). In response, CFO teams of MNEs need to refine company-wide transfer pricing. But doing so won’t be as straightforward as it has been in the past. Significant changes in the world and the emergence of a new normal have made it unusually challenging for MNEs to simply follow the Guidelines on transfer prices without considering the impact on overall business operations.