Nations Still Negotiating Scope of OECD Transfer Pricing Rules (1)

Countries are still discussing a method to determine which transactions fall within the purview, or scope, of Organization for Economic Cooperation and Development transfer pricing rules that seek to simplify the process for certain related-company transactions, an IRS official said Thursday.

Discussions on the scope criteria for the rules are ongoing, Zeb Kelley, senior technical reviewer at the IRS’s International Branch, said in a panel discussion at the 2024 D.C. Bar Tax Conference.

Over 140 countries agreed in 2021 to an OECD-led international tax deal. The pact is made up of two parts: a reallocation of multinational companies’ residual ...