OECD: Transfer pricing guidelines for multinational enterprises and tax administrations

Guidance on the application of the “arm’s length principle”

Guidance on the application of the “arm’s length principle”

The Organisation for Economic Cooperation and Development (OECD) today released the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022.

According to the OECD release, the transfer pricing guidelines provide guidance on the application of the “arm’s length principle,” which represents the international consensus on the valuation, for income tax purposes, of cross-border transactions between associated enterprises.

The 2022 edition of the guidelines consolidates into a single publication the changes to the 2017 edition resulting from:

  • The report Revised Guidance on the Transactional Profit Split Method
  • The report Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles
  • The report Transfer Pricing Guidance on Financial Transactions
  • The consistency changes to the rest of the OECD Transfer Pricing Guidelines needed to produce this new consolidated version of the Transfer Pricing Guidelines


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