Pillar One, Pillar Two, Transfer Pricing and the Arm’s Length Principle: A Tangled Web of New and Old Taxing Rules

Abstract

The OECD Inclusive Framework introduced the Two-Pillar solution – intended to coexist with the current tax framework – to address challenges in an evolving economy. The interaction between the new and old rules may create tensions. This article examines potential tensions between the Pillars and existing transfer pricing rules.