Domestic Transfer Pricing: Global Neglect?

Journal
Sharma, K. (Kuldeep); Kantamneni, S.
International; OECD
Bulletin for International Taxation 2025 (Volume 79), No. 4
Price USD 45

The transfer pricing (TP) landscape is dominated by cross-border transactions. This article discusses the relevance of domestic transfer pricing (DTP), including potential base erosion from interaction with cross-border transactions. The authors examine the interplay of DTP with GloBE rules and make suggestions for improving DTP regulations, based on an analysis of regimes around the world.