2011 review: transfer pricing

In 2011 some of the fundamentals which the transfer pricing world has come to rely upon have been seriously called into question. If proposals tabled by the European Commission in March 2011 were to be adopted, the Common Consolidated Corporate Tax Base (CCCTB) would effectively replace transfer pricing with a system of formulary apportionment across the European Union Member States that adopted it. 2011 saw the commencement of the OECD’s project on the Transfer Pricing Aspects of Intangibles. There were also some signs in 2011 of the diminishing role of the OECD in formulating policy and practice which would represent a fundamental change in transfer pricing across the globe