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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010

This book provide guidance on the application of the "arm’s length principle", which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises.

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In the 2010 edition, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines.

Table of Contents

Foreword

Preface

Glossary

The Arm's Length Principle

Transfer Pricing Methods

Comparability Analysis

Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes

Documentation

Special Considerations for Intangible Property

Special Considerations for Intra-Group Services

Cost Contribution Arrangements

Transfer Pricing Aspects of Business Restructurings

Annex to the OECD Transfer Pricing Guidelines

Annex I to Chapter II. Sensitivity of Gross and Net Profit Indicators

Annex II to Chapter II. Example to Illustrate the Application of the Residual Profit Split Method

Annex III to Chapter II. Illustration of Different Measures of Profits When Applying a Transactional Profit Split Method

Annex to Chapter III. Example of a Working Capital Adjustment

Annex to Chapter IV. Guidelines for Conducting Advance Pricing Arrangements under the Mutual Agreement Procedure ("MAP APAs")

Annex to Chapter VI. Examples to Illustrate the Guidance on Intangible Property and Highly Uncertain Valuation

Appendix. Recommendation of the Council on the Determination of Transfer Pricing between Associated Enterprises [C(95)126/Final]

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