TPguidelines

These Guidelines focus on the main issues of principle that arise in the transfer pricing area. The Committee on Fiscal Affairs intends to continue its work in this area. A revision of Chapters I-III and a new Chapter IX were approved in 2010, reflecting work undertaken by the Committee on comparability, on transactional profit methods and on the transfer pricing aspects of business restructurings. In 2013, the guidance on safe harbours was also revised in order to recognise that properly designed safe harbours can help to relieve some compliance burdens and provide taxpayers with greater certainty. In 2016, these Guidelines were substantially revised in order to reflect the clarifications and revisions agreed in the 2015 BEPS Reports on Actions 8-10 Aligning Transfer pricing Outcomes with Value Creation and on Action 13 Transfer Pricing Documentation and Country-by- Country Reporting. In 2018, a revision of the guidance on the application of the profit split method in Chapter II was approved, as well as the addition of a new annex to Chapter VI which provides guidance for tax administrations on the application of the approach to hard-to-value intangibles. Finally, in 2020 a new Chapter X was added to these Guidelines to incorporate guidance on the transfer pricing aspects of financial transactions. The Committee intends to have regular reviews of the experiences of OECD member and selected non-member countries in applying the arm’s length principle in order to identify areas on which further work could be necessary.