UK and International Tax news

OECD Releases Latest Edition Of Transfer Pricing Guidelines

Friday 21st January 2022

The OECD has released the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.OECD’s Transfer Pricing Guidelines provide guidance on the application of the arm’s length principle which represents the international consensus on the valuation, for income tax purposes, of cross-border transactions between associated enterprises.

This January 2022 edition includes the revised guidance in three areas:

  • on the application of the transactional profit split method approved in June 2018, replacing the guidance in Chapter II
  • on the guidance for tax administrations on the application of the approach to hard-to-value intangibles also agreed in June 2018 and now included as Annex II to Chapter VI
  • on financial transactions approved in January 2020 and now included in Chapter I and a new Chapter X

There are also consistency changes to the rest of the Transfer Pricing Guidelines, which were approved on 7 January 2022.

For more information on the above, please contact Keith Rushen on 0207 486 2378.

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