On 10 July 2017, the Organisation for Economic Co-operation and Development (OECD) released the latest edition of its Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“the Manual” or “OECD TPG”).
The Manual was originally published by the OECD Council in 1995 and was subsequently updated in 1996 and 1997. Prior to the release of the 2017 edition, the last revision to the Manual was made in 2010.
The 2017 edition of the Manual reflects a number of agreed revisions based on the outcome of the OECD/G20’s 2015 Base Erosion and Profit Shifting (BEPS) project. It is believed that these revisions will provide taxpayers with greater certainty and align transfer pricing (TP) outcomes with value creation.
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