The OECD Transfer Pricing Guidelines for Multinational Enterprise and Tax Administrations provide guidance on the application of the “arm’s length principle”. In a global economy where multinational enterprises play a prominent role, Transfer Pricing continues to be high on the agenda of tax administrations and taxpayers alike.
The new 2022 edition incorporates:
- revised guidance on the application of the transactional profit method adopted in 2018,
- guidance for tax administration on the application of the approach to hard-to-value intangibles agreed in 2018,
- guidance on financial transactions approved in 2020, and
- consistency changes have been made to the rest of the OECD Transfer Pricing Guidelines.