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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

Author: OECD
Publisher: OECD Publishing
ISBN: 9789264526914

Previous Edition ISBN: 9789264262737
Published In: March 2022
Format: Paperback
Jurisdiction: France ? Disclaimer:
Countri(es) stated herein are used as reference only

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Description
Contents

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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