International Tax

Transfer Pricing: OECD Transfer Pricing Rules and Guidelines (Portfolio 6936)

  • This Portfolio describes and interprets the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations of the Organization for Economic Cooperation and Development (OECD), as last revised in 2010.


Practitioners will most often encounter the Guidelines in tax audits and competent authority proceedings where the Guidelines are used to shed light on the transfer pricing regulations of a particular country or to reconcile seemingly contradictory transfer pricing rules of two countries. The OECD Guidelines were heavily influenced by transfer pricing developments in the United States, and the Portfolio draws attention to analogs and potential discrepancies between the Guidelines and the U.S. transfer pricing regulations. The Guidelines are organized into ten chapters with alphabetically lettered subchapters; this Portfolio discusses the chapters in order for ease of reference.


Table of Contents

I. Introduction

II. Chapter I of the Guidelines: The Arm’s Length Principle

III. Transfer Pricing Methods

IV. Comparability Analysis

V. Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes

VI. Documentation

VII. Special Considerations for Intangible Property

VIII. Special Considerations for Intra-Group Services

IX. Cost Contribution Arrangements

X. Transfer Pricing Aspects of Business Restructurings

XI. Transfer Pricing Guidance on Financial Transactions

Samuel Maruca
Covington & Burling LLP
Headshot of Michael Mcdonald
Michael McDonald, Ph.D.
Executive Director - National Tax
Ernst & Young LLP
Headshot of Jason M. Osborn
Jason M. Osborn
Mayer Brown LLP
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