OECD Data Depicts Profit-Shifting Fight: Transfer Pricing Report

December 5, 2025, 10:02 AM UTC

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re looking at the oodles of data the OECD dumped last week about how BEPS is doing at clamping down on profit shifting—and the verdict seems to be...it’s doing OK?

The upshot: Things seem to be getting a bit better since BEPS began. Companies appear to be paying more in taxes and doing modestly less profit shifting over the years—though investment hubs continue to see an interestingly high amount of profit per employee and share of related-party revenue.

The OECD’s report chronicles the steps countries have ...

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