Transfer pricing / Advanced
OECD Transfer Pricing Guidelines 2022
The OECD’s consolidated 2022 guidance on applying the arm’s length principle to transactions between associated enterprises.
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The T&M reading note
Why it deserves your time
A core technical reference for delineation, comparability, methods and transfer-pricing documentation.
A suggested 15-minute first pass
Where to begin
- Start with the arm’s length principle.
- Use the relevant methods and comparability chapters.
- Read the chapter relevant to the transaction type.
Read this edition in context
Foundational consolidated edition. Read alongside later OECD supplements, including Amount B, and applicable domestic rules.
These notes describe the publication; they do not determine the treatment of a particular taxpayer or transaction.
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Official sourcewww.oecd.org Catalogue review: 2026-10-13