OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administration 2022

Abstract

The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 provide guidance on the application of the arm's length principle, which is the international consensus on the valuation of cross-border transactions between associated enterprises. These guidelines help governments ensure that taxable profits of multinational enterprises (MNEs) are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs reflects the economic activity undertaken therein.