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Unlocking global tax insights: Deloitte & OECD discuss transfer pricing

In this exclusive interview, Deloitte's Alison Lobb and Ralf Heussner met with Manuel de los Santos, Head of the OECD Transfer Pricing Unit, to discuss the latest OECD projects and upcoming transfer pricing initiatives.

Manuel de los Santos, Head of the OECD Transfer Pricing Unit, sat down with Deloitte’s Alison Lobb, Partner and Ralf Heussner, Partner, in Paris in late October 2023 to chat about his role at the OECD and everything transfer pricing.

A must-watch for anyone navigating the complexities of transfer pricing


Watch our exclusive interview with Manuel de los Santos, Head of the OECD Transfer Pricing Unit, in full or split into two parts.

You’ll hear the latest on:


  • Pillar One, Amount An and Amount B and Pillar Two
  • 2010 report on the attribution of profits to permanent establishments
  • Cross-border remote working
  • Transfer pricing audits and dispute resolution mechanisms
  • And other hot transfer pricing topics

Since 2021, I started leading the Transfer Pricing team, which is an experience I am enjoying the most, though I have to recognise that it is also a big responsibility since Transfer Pricing is almost everywhere in international tax, not only within the OECD but—if you look at business and stakeholders—there is a lot interest in Transfer Pricing, which, I think, makes things fun but also challenging.

Manuel de los Santos, Head of the OECD Transfer Pricing Unit

Full interview

Unlocking global tax insights: Deloitte & OECD discuss transfer pricing

Part one

• Pillar One

• Pillar Two

Part two

• AOA/2010 PE Report

• Global Mobility

• Dispute prevention/resolution

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