A new chapter on financial transactions is in the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations,
which are widely followed. 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. The OECD is headquartered in France.
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