On 20 January 2022, the Organisation for Economic Co-operation
and Development (OECD) released the 2022 edition of the OECD
Transfer Pricing Guidelines for Multinational Enterprises and Tax
Administrations (TP Guidelines).
In the new TP Guidelines, released after a span of five years,
the OECD has consolidated the following three reports developed
over the last couple of years to the 2017 TP Guidelines.
- The report, Revised Guidance on the transactional
Profit Split Method, was approved on 4 June 2018. This
report has replaced the Guidance in Chapter II, Section C
(paragraphs 2.114-2.151) found in the 2017 Transfer Pricing
Guidelines and Annexes II and III to Chapter II.
This Guidance aims to clarify when the transactional Profit Split
Method is the Most Appropriate Method (MAM) to apply. It also
explains how the Profit Split Method should be applied and includes
several examples illustrating the principles discussed.
