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Transfer Pricing Guidelines ...

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The OECD releases the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.

In a global economy where multinational entreprises (NMEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their juridiction ant that the tax base reported bij MNEs in their country reflects th economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.

The OECD Transfer Pricing Guidelines for Multinational Enterprise and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation for tax purposes of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing continues to be high on the agenda of tax administrations and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of the arm’s length remuneration for their cross-border transactions with associated enterprises.

For more information on the OECD Transfer Pricing Guidelines, visit https://oe.cd/tpg2022

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 : the guide


OCDE (2022), OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022, Éditions OCDE, Paris, https://doi.org/10.1787/0e655865-en.

This latest edition consolidates into a single publication the changes to the 2017 edition of the Transfer Pricing Guidelines resulting from:

This January 2022 edition includes the revised guidance on the application of the transactional profit method and the guidance for tax administrations on the application of the approach to hard-to-value intangibles agreed in 2018, as well as the new transfer pricing guidance on financial transactions approved in 2020.

Finally, consistency changes have been made to the rest of the OECD Transfer Pricing Guidelines.

The OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995.

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Source: OECD, Tax, "OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations".

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