The OECD has today released the 2022 edition of the OECD Transfer Pricing Guidelines for multinational enterprises and tax administrations. The consolidated guidelines now include various workstreams approved by the OECD and G20 under the base erosion and profit shifting (BEPS) program, with a new Chapter X containing the latest guidance on financial transactions, alongside updates in relation to the use of the transactional profit split method and commentary on hard-to-value intangibles.

Please feel free to contact our transfer pricing team who will be happy to discuss the specifics of the of the changes.