Preface
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...
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The authoritative international guidance on arm's length pricing for transactions between associated enterprises. Full searchable text with paragraph references.
The OECD Transfer Pricing Guidelines provide internationally agreed principles and approaches for pricing transactions between associated enterprises. These guidelines are the primary reference for tax administrations and taxpayers worldwide when determining arm's length pricing and resolving transfer pricing disputes.
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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...
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...
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...
Content from Chapter II: Transfer pricing methods
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...
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...
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...
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...
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...
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...
Content from Chapter IX: Transfer pricing aspects of business restructurings
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...
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...
See Chapter II, Part III, Section B of these Guidelines for general guidance on the application of the transactional net margin method.
See Chapter II, Part III, Section C of these Guidelines for general guidance on the application of the profit split method.
See Chapter III, Section A.6 of these Guidelines for general guidance on comparability adjustments.
Content from Annex I to Chapter IV: Sample Memoranda of Understanding for Competent Authorities to establish bilateral safe harbours
Content from Annex II to Chapter IV: Guidelines for conducting Advance Pricing Arrangements under the Mutual Agreement Procedure (MAP APAs)
The following information should be included in the master file:
The following information should be included in the local file:
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...
Content from Annex IV to Chapter V: Country-by-Country Reporting Implementation Package
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...
Content from Annex II to Chapter VI: Guidance for tax administrations on the application of the approach to hard-to-value intangibles
Content from Annex to Chapter VIII: Examples to illustrate the guidance on cost contribution arrangements
Practical guides and key definitions that reference the OECD Guidelines
The arm's length principle, central to international tax and transfer pricing, seems intuitive—price transactions between related entities as if they were independent—but applying it in practice is notoriously complex.
Everything you need to know about transfer pricing documentation in one place: the three-tiered framework, jurisdiction requirements, transaction-specific guides, and common mistakes. From BEPS Action 13 to audit defense—your complete documentation roadmap.
Business restructurings trigger intensive transfer pricing scrutiny. Learn what documentation you need before, during, and after a restructuring—including exit charge calculations, valuation requirements, and how to avoid common pitfalls that invite audit adjustments.
Strong intangibles documentation, consistent with OECD Chapter VI (intangibles) and Chapter V (documentation), requires identifying all relevant IP, distinguishing legal ownership from entitlement to returns using the DEMPE framework, and ensuring arm's length compensation for each contributor. This guide covers DEMPE analysis, valuation approaches, hard-to-value intangibles, CCAs, and common documentation gaps.
Financial transaction documentation must address accurate delineation, borrower creditworthiness, arm's length terms, and whether the arrangement would occur between independent parties. This guide covers OECD Chapter X requirements for intercompany loans, guarantees, and cash pooling—with practical examples and common documentation weaknesses.
Intercompany agreements provide legal substance to transfer pricing arrangements and are essential audit documentation. Learn the essential terms, transaction-specific requirements, execution best practices, and common mistakes to avoid for TP compliance.
First published in 1995 and regularly updated, the OECD Transfer Pricing Guidelines represent the international consensus on how associated enterprises should price their cross-border transactions. The guidelines are referenced by over 140 countries and form the basis of most domestic transfer pricing legislation worldwide.
ArmsLength AI helps you apply these principles in practice with AI-powered benchmarking studies that follow OECD best practices.