OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
2022
In a global economy where multinational enterprises (MNEs) play a prominent role,
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. The OECD Transfer Pricing Guidelines
provide guidance on the application of the “arm’s length principle”, which is the
international consensus on the valuation of cross-border transactions between associated
enterprises.
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.
Published on January 20, 2022Also available in: French