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OECD Transfer Pricing Guidelines

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Chapter	Focus	Sections	Paragraphs	Open
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...	1	19	Read
Glossary	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	49	Read
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	193	Read
Chapter II	Transfer pricing methods Content from Chapter II: Transfer pricing methods	13	187	Read
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	83	Read
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	179	Read
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	62	Read
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	212	Read
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	65	Read
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	53	Read
Chapter IX	Transfer pricing aspects of business restructurings Content from Chapter IX: Transfer pricing aspects of business restructurings	15	131	Read
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	227	Read
Annex	Annex to the OECD Transfer Pricing Guidelines: 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	24	Read
Annex I to Chapter II	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	8	Read
Annex II to Chapter II	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	88	Read
Annex to Chapter III	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	12	Read
Annex I to Chapter IV	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	58	Read
Annex II to Chapter IV	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	87	Read
Annex I to Chapter V	Annex I to Chapter V: Transfer pricing documentation – Master file The following information should be included in the master file:	1	6	Read
Annex II to Chapter V	Annex II to Chapter V: Transfer pricing documentation – Local file The following information should be included in the local file:	1	5	Read
Annex III to Chapter V	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	23	Read
Annex IV to Chapter V	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	143	Read
Annex I to Chapter VI	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	111	Read
Annex II to Chapter VI	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	39	Read
Annex to Chapter VIII	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	22	Read

Context

How to use this source effectively

Use this page as your technical baseline, then move to practical guides and glossary definitions for execution.

The OECD Guidelines are the international reference for arm's length pricing. They provide the legal and analytical foundation used by tax administrations and taxpayers across jurisdictions.

Use chapter-level navigation when analyzing methods, comparability, documentation, intangibles, services, restructurings, or financial transactions. Use full-text search when you need a paragraph-level citation.

Citation format

Use: OECD Transfer Pricing Guidelines, para. X.XX (2022).

Practical guides

Arm's Length Principle: Definition, Examples & OECD Guidelines (2025)Arm's Length Transaction: Definition, Examples & How to Verify Compliance Transfer Pricing Policy: How to Create and Document Your TP Framework Transfer Pricing Documentation: The Complete Guide to Master File, Local File & CbCR (2025)

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Key terms

Arm's Length Principle Country-by-Country Report Local File Master File Tested Party Working Capital Adjustment

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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...