The Organisation for Economic Co-operation and Development (OECD) on Jan. 20 released new transfer pricing guidelines (the “OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration 2022”) that provide key information on the application of the “arm’s-length principle,” which represents the international consensus on the valuation of cross-border transactions between associated enterprises for income purposes.
The updated guidelines provide additional clarity on several important transfer pricing issues—including determining whether the profit-split method is appropriate, and guidance for tax administrators regarding hard-to-value intangibles.
The 2022 edition of the guidelines also consolidates three reports that modified the previous 2017 edition of the guidelines:
- The 2018 report on revised guidance on the transactional profit split method
- The 2018 report on guidance for tax administrations on the application of the approach to hard-to-value intangibles
- The 2020 report on transfer pricing guidance on financial transactions.
Contact:
Tax professional standards statement
This content supports Grant Thornton LLP’s marketing of professional services and is not written tax advice directed at the particular facts and circumstances of any person. If you are interested in the topics presented herein, we encourage you to contact us or an independent tax professional to discuss their potential application to your particular situation. Nothing herein shall be construed as imposing a limitation on any person from disclosing the tax treatment or tax structure of any matter addressed herein. To the extent this content may be considered to contain written tax advice, any written advice contained in, forwarded with or attached to this content is not intended by Grant Thornton LLP to be used, and cannot be used, by any person for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code.
The information contained herein is general in nature and is based on authorities that are subject to change. It is not, and should not be construed as, accounting, legal or tax advice provided by Grant Thornton LLP to the reader. This material may not be applicable to, or suitable for, the reader’s specific circumstances or needs and may require consideration of tax and nontax factors not described herein. Contact Grant Thornton LLP or other tax professionals prior to taking any action based upon this information. Changes in tax laws or other factors could affect, on a prospective or retroactive basis, the information contained herein; Grant Thornton LLP assumes no obligation to inform the reader of any such changes. All references to “Section,” “Sec.,” or “§” refer to the Internal Revenue Code of 1986, as amended.
More tax hot topics
No Results Found. Please search again using different keywords and/or filters.