A new edition of the OECD Guidelines

A new edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations was published in 2022.

The new release contains the following changes:

  • In Chapter II, which refers to the application of profit split method, it is explained exactly where the profit sharing method is applicable
  • In Chapter VI, an annex was added that refers to hard to value intangibles
  • A new chapter X is added which is related to financial transactions