Transparency and Documentation in Transfer Pricing 2024

June 19, 2024


In 2024, Transfer Pricing transparency and documentation are critical for multinationals seeking to comply with global tax regulations. This article explores the requirements and benefits of Country by Country Report (CbCR) and other standardized documentation regulations, driven by the OECD and adopted globally.  

Country by Country Report (CbCR)  

The CbCR has become an essential tool for improving tax transparency. Multinational companies must report revenues, taxes paid and other key economic measures in each jurisdiction where they operate. This level of detail allows tax authorities to better assess how companies structure their global operations and distribute their income.  

Benefits of CbCR:  

  • Enhanced Transparency: Provides a clear view of the economic and tax activities of multinationals.  
  • Reduced Tax Evasion: Helps prevent tax evasion by identifying discrepancies in profit allocation and taxation.  
  • Global Compliance: Aligns company practices with international regulatory expectations.  

Global Implementation  

Many countries are integrating CbCR requirements into their local laws. This move toward greater transparency and standardization reflects a global effort to combat tax evasion and ensure that profits are taxed where economic activities are generated.  

Examples of Implementation:  

  • European Union: All member states have adopted the CbCR and are implementing additional regulations to ensure international tax transparency.  
  • Latin America: Countries such as Brazil and Mexico have updated their regulations to align with OECD guidelines.  
  • Asia and Africa: They are in the process of adjusting their local regulations to comply with international transparency standards.  


Transfer Pricing transparency and documentation are crucial for multinationals in 2024. Adopting these practices not only ensures compliance with global tax regulations, but also strengthens the position of companies in tax audits and reduces the risk of adjustments and penalties.