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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022

Name: OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022
Brand: OECD Publishing
SKU: 9789264526914
Availability: InStock
Author: OECD
ISBN: 9789264526914

By OECD

OECD Publishing March 2022

Specifications

ISBN-13: 9789264526914
Publisher: OECD Publishing
Publication: March 2022
Format: Paperback
Jurisdiction: France ? Countri(es) for reference only

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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.

Foreword

Preface

Abbreviations and Acronyms

Glossary

The Arm's Length Principle

Transfer Pricing Methods

Comparability Analysis

Administrative approaches to avoiding and resolving transfer pricing disputes

Documentation

Special Considerations for Intangibles

Special Considerations for Intra-Group Services

Cost Contribution Arrangements

Transfer Pricing Aspects of Business Restructurings

Transfer pricing aspects of financial transactions

Annexes

Annex to the OECD Transfer Pricing Guidelines

Annex I to Chapter II. Sensitivity of Gross and Net Profit Indicators

Annex II to Chapter II. Examples to illustrate the guidance on the transactional profit split method

Annex to Chapter III. Example of a working capital adjustment

Annex I to Chapter IV. Sample Memoranda of Understanding for Competent Authorities to establish bilateral safe harbours

Annex II to Chapter IV. Guidelines for conducting Advance Pricing Arrangements under the Mutual Agreement Procedure (MAP APAs)

Annex I to Chapter V. Transfer pricing documentation – Master file

Annex II to Chapter V. Transfer pricing documentation – Local file

Annex III to Chapter V. Transfer pricing documentation – Country‑by‑Country Report

Annex IV to Chapter V. Country-by-Country Reporting Implementation Package

Annex I to Chapter VI. Examples to illustrate the guidance on intangibles

Annex II to Chapter VI. Guidance for tax administrations on the application of the approach to hard-to-value intangibles

Annex to Chapter VIII. Examples to illustrate the guidance on cost contribution arrangements

Appendix. Recommendation of the Council on the Determination of Transfer Pricing between Associated Enterprises [C(95)126/Final, as amended

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