OECD Transfer Pricing Guidelines 2022
Search the January 2022 edition by chapter and paragraph, then verify quotations and citations against the official OECD publication.
- Main chapters
- 10
- Annexes
- 13
- Paragraphs
- 2,086
OECD publication · January 2022 edition · 659 pages
Official-source details last checked 16 August 2026.
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A compact view of all OECD guidance chapters, including scope and paragraph volume.
Front matter2
Preface
The role of multinational enterprises (MNEs) in world trade has continued to increase dramatically since the adoption of these Guidelines in 1995. This in part reflects the increased pace of...
1 section · 19 ¶Glossary
An arrangement that determines, in advance of controlled transactions, an appropriate set of criteria (e.g. method, comparables and appropriate adjustments thereto, critical assumptions as to future...
1 section · 49 ¶
Chapters10
Chapter I
The arm’s length principle
This Chapter provides a background discussion of the arm’s length principle, which is the international transfer pricing standard that OECD member countries have agreed should be used for tax...
4 sections · 193 ¶- 13 sections · 187 ¶
- Part I: Selection of the transfer pricing method
- A. Selection of the most appropriate transfer pricing method to the circumstances of the case2.1
- B. Use of more than one method2.12
- Part II: Traditional transaction methods
- A. Introduction2.13
- B. Comparable uncontrolled price method2.14
- C. Resale price method2.27
- D. Cost plus method2.45
- Part III: Transactional profit methods
- A. Introduction2.62
- B. Transactional net margin method2.64
- C. Transactional profit split method2.114
- D. Conclusions on transactional profit methods2.184
Chapter III
Comparability analysis
General guidance on comparability is found in Section D of Chapter I. By definition, a comparison implies examining two terms: the controlled transaction under review and the uncontrolled...
3 sections · 83 ¶Chapter IV
Administrative approaches to avoiding and resolving transfer pricing disputes
This chapter examines various administrative procedures that could be applied to minimise transfer pricing disputes and to help resolve them when they do arise between taxpayers and their tax...
7 sections · 179 ¶Chapter V
Documentation
This chapter provides guidance for tax administrations to take into account in developing rules and/or procedures on documentation to be obtained from taxpayers in connection with a transfer pricing...
5 sections · 62 ¶Chapter VI
Special considerations for intangibles
Under Article 9 of the OECD Model Tax Convention, where the conditions made or imposed in the use or transfer of intangibles between two associated enterprises differ from those that would be made...
5 sections · 212 ¶- Introduction6.1
- A. Identifying intangibles6.5
- B. Ownership of intangibles and transactions involving the development, enhancement, maintenance, protection and exploitation of intangibles6.32
- C. Transactions involving the use or transfer of intangibles6.86
- D. Supplemental guidance for determining arm’s length conditions in cases involving intangibles6.107
Chapter VII
Special considerations for intra-group services
This chapter discusses issues that arise in determining for transfer pricing purposes whether services have been provided by one member of an MNE group to other members of that group and, if so, in...
4 sections · 65 ¶Chapter VIII
Cost contribution arrangements
This chapter discusses cost contribution arrangements (CCAs) between two or more associated enterprises. The purpose of the chapter is to provide some general guidance for determining whether the...
5 sections · 53 ¶Chapter IX
Transfer pricing aspects of business restructurings
Content from Chapter IX: Transfer pricing aspects of business restructurings
15 sections · 131 ¶- Introduction9.1
- B. Applying Article 9 of the OECD Model Tax Convention and these Guidelines to business restructurings: theoretical framework9.9
- Part I: Arm's length compensation for the restructuring itself
- A. Introduction9.10
- B. Understanding the restructuring itself9.13
- C. Recognition of the accurately delineated transactions that comprise the business restructuring9.34
- D. Reallocation of profit potential as a result of a business restructuring9.39
- E. Transfer of something of value (e.g. an asset or an ongoing concern)9.48
- F. Indemnification of the restructured entity for the termination or substantial renegotiation of existing arrangements9.75
- Part II: Remuneration of post-restructuring controlled transactions
- A. Business restructurings versus "structuring"9.98
- B. Application to business restructuring situations: selection and application of a transfer pricing method for the post-restructuring controlled transactions9.108
- C. Relationship between compensation for the restructuring and post-restructuring remuneration9.114
- D. Comparing the pre- and post-restructuring situations9.117
- E. Location savings9.126
Chapter X
Transfer pricing aspects of financial transactions
The purpose of this chapter is to provide guidance for determining whether the conditions of certain financial transactions between associated enterprises are consistent with the arm’s length...
5 sections · 227 ¶
Annexes13
Annex
Guidelines for monitoring procedures on the OECD Transfer Pricing Guidelines and the involvement of the business community
In July 1995, the OECD Council approved for publication the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“the Guidelines”), submitted by the Committee on Fiscal...
3 sections · 24 ¶Annex I to Chapter II
Sensitivity of gross and net profit indicators
See Chapter II, Part III, Section B of these Guidelines for general guidance on the application of the transactional net margin method.
1 section · 8 ¶Annex II to Chapter II
Examples to illustrate the guidance on the transactional profit split
See Chapter II, Part III, Section C of these Guidelines for general guidance on the application of the profit split method.
1 section · 88 ¶Annex to Chapter III
Example of a working capital adjustment
See Chapter III, Section A.6 of these Guidelines for general guidance on comparability adjustments.
1 section · 12 ¶Annex I to Chapter IV
Sample Memoranda of Understanding for Competent Authorities to establish bilateral safe harbours
Content from Annex I to Chapter IV: Sample Memoranda of Understanding for Competent Authorities to establish bilateral safe harbours
1 section · 58 ¶Annex II to Chapter IV
Guidelines for conducting Advance Pricing Arrangements under the Mutual Agreement Procedure (MAP APAs)
Content from Annex II to Chapter IV: Guidelines for conducting Advance Pricing Arrangements under the Mutual Agreement Procedure (MAP APAs)
5 sections · 87 ¶Annex I to Chapter V
Transfer pricing documentation – Master file
The following information should be included in the master file:
1 section · 6 ¶Annex II to Chapter V
Transfer pricing documentation – Local file
The following information should be included in the local file:
1 section · 5 ¶Annex III to Chapter V
Transfer pricing documentation – Country-by-Country Report
Table 1. Overview of allocation of income, taxes and business activities by tax jurisdiction Name of the MNE group: Fiscal year concerned: Currency used: | Tax Jurisdiction | Revenues - Unrelated...
3 sections · 23 ¶Annex IV to Chapter V
Country-by-Country Reporting Implementation Package
Content from Annex IV to Chapter V: Country-by-Country Reporting Implementation Package
6 sections · 143 ¶- Country-by-Country Reporting Implementation Package
- Model legislation related to Country-by-Country Reporting1
- Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports
- Annex to the Agreement – Confidentiality and Data Safeguards Questionnaire
- Competent Authority Agreement on the Exchange of Country-by-Country Reports on the basis of a Double Tax Convention (“DTC CAA”)
- Competent Authority Agreement on the Exchange of Country-by-Country Reports on the basis of a Tax Information Exchange Agreement (“TIEA CAA”)
Annex I to Chapter VI
Examples to illustrate the guidance on intangibles
Premiere is the parent company of an MNE group. Company S is a wholly owned subsidiary of Premiere and a member of the Premiere group. Premiere funds R&D and performs ongoing R&D functions in support...
29 sections · 111 ¶- Example 11
- Example 25
- Example 38
- Example 410
- Example 513
- Example 614
- Example 716
- Example 820
- Example 926
- Example 1030
- Example 1135
- Example 1239
- Example 1342
- Example 1446
- Example 1549
- Example 1654
- Example 1759
- Example 1864
- Example 1967
- Example 2069
- Example 2173
- Example 2278
- Example 2383
- Example 2486
- Example 2589
- Example 2692
- Example 2797
- Example 28101
- Example 29104
Annex II to Chapter VI
Guidance for tax administrations on the application of the approach to hard-to-value intangibles
Content from Annex II to Chapter VI: Guidance for tax administrations on the application of the approach to hard-to-value intangibles
3 sections · 39 ¶Annex to Chapter VIII
Examples to illustrate the guidance on cost contribution arrangements
Content from Annex to Chapter VIII: Examples to illustrate the guidance on cost contribution arrangements
1 section · 22 ¶
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