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 nine 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. Traditional Methods

IV. Other Methods

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

Robert Culbertson
Partner - Tax Practice
Covington & Burling LLP
Samuel Maruca
Covington & Burling LLP
William Chip
Senior Counselor to the Secretary of Homeland Security
U.S. Department of Homeland Security