Transfer pricing update

June and July have been busy months for the EU and OECD with respect to transfer pricing. The OECD is putting pen to paper on changes to transfer pricing guidance, as set out below; and the EU has confirmed a strong commitment to ensuring that a fair share of tax is paid in locations that generate profits. Despite the continued rhetoric around multinational entities paying a fair share of tax, clarifications in relation to international transfer pricing guidance and the forthcoming certainty around patent box regimes will free those multinational entities to implement commercially based structures across borders that comply with local regulations.