Transfer pricing: quarterly review of developments

This update sets out a summary of key changes to international transfer pricing guidance, regulations and case law that have occurred in the past few months. The changes are dominated by the final BEPS reports for transfer pricing Actions 8, 9 and 10; however, some important legislative changes should also be considered. There has also been a landmark ruling in Australia in relation to the value of an explicit loan guarantee versus implicit value (with some important extensions to the 2009 GE case principles, despite this case not being mentioned in the ruling).