Worldwide Transfer Pricing Reference Guide 2022-23

The EY Worldwide Transfer Pricing Reference Guide 2022-23 is a publication designed to help international tax executives identify transfer pricing rules, practices and approaches. These must be understood for a company to carry out both transfer pricing compliance and planning activities in the base erosion and profit shifting (BEPS)1 era.

Transfer pricing rules and regulations around the world continue to grow in number and complexity. Practitioners need to have current knowledge of a complex web of jurisdiction tax laws, regulations, rulings, methods and requirements.

The information included in the EY Worldwide Transfer Pricing Reference Guide 2022-23 covers 123 jurisdictions. It is meant to provide an overview for the covered jurisdictions regarding their transfer pricing tax laws, regulations and rulings; Organization for Economic Co-operation and Development (OECD) Guidelines treatment; documentation requirements; transfer pricing returns and related-party disclosures; transfer pricing documentation and disclosure timelines; BEPS Action 13 requirements; transfer pricing methods; benchmarking requirements; transfer pricing penalties and relief from penalties; statutes of limitations on transfer pricing assessments; possibility of transfer pricing scrutiny and related audits by the tax authorities; and opportunities for advance pricing agreements (APAs).

This publication should not be regarded as offering a complete explanation of the matters referred to and is subject to changes in laws and other applicable rules, in addition to the overall business environment in each jurisdiction.