New edition of transfer pricing guidelines issued

The OECD on 20 January 2022 issued a new edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations to replace the version issued in 2017.

This version of the guidelines does not introduce any new guidance; rather, it consolidates into one publication previously issued guidance, including:

Revised guidance on the transactional profit split method, which had been approved by the OECD/G20 Inclusive Framework on BEPS on 4 June 2018;
Guidance on the application of the approach to hard-to-value intangibles, also approved by the Inclusive Framework on 4 June 2018; and
Guidance on financial transactions, which had been adopted by the Inclusive Framework on 20 January 2020.

The new version of the guidelines also reflects some changes that were made for consistency and that were approved by the Inclusive Framework on 7 January 2022.

Laurie Dicker
ldicker@bdo.com