OECD Releases New Edition of Transfer Pricing Guidelines

The OECD on January 20 issued a new edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.

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 June 4, 2018;

  • Guidance on the application of the approach to hard-to-value intangibles, also approved by the Inclusive Framework on June 4, 2018; and

  • Guidance on financial transactions, which had been adopted by the Inclusive Framework on January 20, 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 January 7, 2022.

The 2022 version of the guidelines replaces the version issued in 2017.


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