New 2022 OECD Transfer Pricing Guidelines released

BVWire–UKIssue #35-2
February 15, 2022

A new chapter on financial transactions is in the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, released the last week of January. The preface and glossary have also been updated this year. The new edition reflects the post-2017 revision by the Organisation for Economic Co-operation and Development (OECD) of its profit-split guidance as well as guidance for tax administrations regarding hard-to-value intangibles. Other topics that are relied on for transfer pricing valuations include:

  • Recommendations for structuring and documenting cost contribution arrangements;
  • Performing comparability analyses;
  • A three-tiered approach to documenting transfer pricing conclusions; and
  • Country-by-country reporting implementation packages.
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