Transfer Pricing in the Age of Economic Substance: A Post-BEPS Framework

The OECD's substance-over-form revolution has reshaped transfer pricing analysis. Our members set out a practical framework for groups facing audit.

Analysis 4 April 2026 · WTL Admin

The post-BEPS transfer pricing landscape demands a fundamentally different approach to documentation and defence. Substance, once a peripheral consideration, is now the central axis of the arm's length analysis.

This article sets out a practical, document-led framework for multinational groups preparing for audit under the revised OECD Transfer Pricing Guidelines.

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Transfer Pricing in the Age of Economic Substance: A Post-BEPS Framework

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