2017 OECD Transfer Pricing Guidelines
On 10 July 2017, the long awaited 2017 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2017 Transfer Pricing Guidelines) were released. The new edition counting 612 pages replaces the previous Transfer Pricing Guidelines issued in 2010 (2010 Transfer Pricing Guidelines) and provides new guidance on the application of the arm’s length principle.
- intangibles (newly defined categories, functions, risks and so called DEMPE analysis);
- low value adding intragroup services;
- transfer pricing documentation (a three-tiered approach, i.e. master files, local files and country-by -country reporting);
- application of arm’s length principle;
- comparability factors in transfer pricing, including location savings, assembled workforce and multinational group synergies;
- cost contribution arrangements and their expected benefits.