On January 20th, 2022 the Organisation for Economic
Cooperation and Development (OECD) issued an update to the Transfer
Pricing Guidelines for Multinational Enterprises and Tax
Administrations (Transfer Pricing Guidelines) of 2017.
The OECD has made three significant additions and revisions to
the guidelines for multinational enterprises and tax
administrations, in respect of the transactional profit split
method, hard-to-value intangibles and the aspects financial
transactions reflecting the several enhancements developed over the
last few years. These updates expand the document of Transfer
Pricing Guidelines from 612 pages in 2017 to 658 pages.
The most significant change in the 2022 edition of the TP
Guidelines is the addition of a new Chapter X that includes updated
guidelines and illustrative examples, based on the OECD 2020
reports on Transfer Pricing Guidelines on Financial Transactions:
Base Erosion and Profit-Shifting (BEPS) Actions 4, 8, 9 and 10.
