OECD transfer pricing guidelines

For those of you who are involved in cross-border dealings between associated entities, the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the ‘arm’s length principle’ which is the international consensus on transfer pricing, ie on the valuation for tax purposes of cross-border transactions between associated enterprises.

The January 2022 edition of the OECD Transfer Pricing Guidelines has now been released and 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.

This article from the 'A Week in Review' newsletter was originally published Tuesday 1st February 2022. If you have any questions or would like a second opinion on any national or international tax issues, please contact me [email protected].?

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