Transfer Pricing Guidelines ...

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.​

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

• The report Revised Guidance on the Transactional Profit Split Method, approved by the OECD/G20 Inclusive Framework on BEPS on 4 June 2018, and which replaced the guidance in Chapter II, Section C (paragraphs 2.114-2.151) found in the 2017 Transfer Pricing Guidelines and Annexes II and III to Chapter II;
• The report Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles, approved by the OECD/G20 Inclusive Framework on BEPS on 4 June 2018, which has been incorporated as Annex II to Chapter VI;
• The report Transfer Pricing Guidance on Financial Transactions, adopted by the OECD/G20 Inclusive Framework on BEPS on 20 January 2020, which has been incorporated into Chapter I (new Section D.1.2.2) and in a new Chapter X;
• The consistency changes to the rest of the OECD Transfer Pricing Guidelines needed to produce this consolidated version of the Transfer Pricing Guidelines, which were approved by the OECD/G20 Inclusive Framework on BEPS on 7 January 2022.

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".​