OECD releases 2022 transfer pricing guidelines


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.


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