![]() The 2010 edition also included the addition of Chapter IX on the transfer pricing aspects of business restructurings. ![]() In the 2010 edition, Chapters I-III were substantially revised, with new guidance on: (i) the selection of the most appropriate transfer pricing method for the circumstances of the case (ii) the practical application of transactional profit methods and (iii) the performance of comparability analyses. A limited update was issued in 2009, primarily to reflect the adoption of the arbitration clause in the 2008 update of the Model Tax Convention. ![]() Detailed discussion Backgroundįollowing its first publication in 1979, the original version of the OECD TP Guidelines was approved by the OECD Council in 1995. It also includes some related changes for consistency. It incorporates the following three revisions of the 2017 edition: (i) revised guidance on the transactional profit split method approved by the OECD/Inclusive Framework on BEPS in 2018 (ii) guidance for tax administrations on the application of the approach to Hard-to-Value Intangibles approved in 2018 and (iii) transfer pricing guidance on financial transactions approved in 2020. The 2022 edition of the OECD TP Guidelines mainly reflects a consolidation of a number of reports resulting from the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project. On 20 January 2022, the Organisation for Economic Co-operation and Development (OECD) released the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TP Guidelines).
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