In alignment with the prevailing trends observed in recent years, the year 2023 witnessed notable developments in the transfer pricing landscape across different levels. While some of the legislative and guidance-based changes have reached final stages, their practical implications remain largely untested. Concurrently, other developments are still in incipient stages of development, indicating an ongoing evolution in the international tax landscape. These changes signal a pivotal moment in the evolution of transfer pricing practices, paving the way for a more nuanced and dynamic international tax environment.
