Tax Alert: New TP Guidelines
Yesterday, the January 2022 update of the OECD Transfer Pricing Guidelines has been published. The update incorporates TP guidance on 3 subjects on which reports were published in recent years:
– Transactional profit splits (cf. 2018 report);
– Hard-to-value intangibles (cf. 2018 report);
– Financial transactions (cf. 2020 report).
The effective date of transactions generally determines which TP guidance to use. For guidance on the above 3 subjects, the publication dates of the initial reports may be decisive.
Read more on the OECD website.