On January 20, 2022, the Organization for Economic Co-operation and Development (OECD) issued the new version of the transfer pricing guidelines applicable to multinational enterprises and tax administrations.
In this latest edition, the analysis of intangibles has been prioritized through a report for the “Guidelines for Tax Administrations in their application to the approach to Intangible Assets-Difficult to Assess,” approved by the OECD and G20 Inclusive Framework on BEPS actions.
In addition, a chapter on transfer pricing aspects of financial transactions, taken from the OECD and G20 Inclusive Framework on BEPS actions of January 20 last year, has been included to guide whether the terms of certain transactions are compatible with the arm’s length principle.
Finally, aspects related to the profit split method, also known as the transactional “Profit Split” method, approved by the OECD and G20 Inclusive Framework on BEPS actions of June 4, 2018, and other amendments aimed at providing greater clarity to the treatment of the transfer pricing regime have been added.
Source: OECD 21/01/22
