Tag: ocde

Brazil adopts the arm’s length principle and aligns its transfer pricing regime with OECD guidelines. The reform introduces new valuation methods, stricter documentation requirements, and penalties—marking a key shift for multinationals operating in the country. ALS offers strategic support for implementation and compliance.

The Italian Revenue Agency and the Supreme Court endorse the use of the full range as a valid criterion to determine the arm’s length value in transfer pricing. This position, aligned with OECD guidelines, strengthens legal certainty for multinationals and clarifies the use of full ranges over more restrictive approaches such as the median.