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.

Curious about the updates? Our Transfer Pricing experts Natalie Reypens, Harmen van Dam, Peter Moons and Fabian Sutter are available for queries.