OECD Guidelines – The Nine Step Process

The OECD Nine Step Process

The OECD has identified a process of Nine Steps (“The Nine step Process’’) which illustrates what will usually be involved in conducting a transfer pricing analysis.

The guidelines describe the nine step process as ‘’typical’’ or ‘’accepted good practice’’ and that it is not a compulsory one.

They stress that following the process does not guarantee that the result is arm’s length and notes it is perfectly possible to arrive at an arm’s length result by following a different process.