OECD Transfer Pricing Guidelines
The current Guidelines (2017/2022 edition) topic by topic — aligned with the reader's map: the ALP, method selection, comparability, the five method families, intangibles, services, financials, restructuring, range statistics and documentation.
OECD General Principles: The Arms-Length Standard
Chapter 1 of the OECD Guidelines: the ALP as the standard behind s.92(1) and Article 9, the controlled-transaction concept, and the primary and correlative adjustment machinery.
Read docOECD Method Selection: Tested Party, PLIs and the Best Method
Chapter 2 of the OECD Guidelines: tested party selection at 2.48, the PLI list and selection logic at 2.50-2.53, and the five methods and best-methods rule at 2.62-2.80.
Read docOECD Comparability: The Five Factors and the Two Screens
Chapter 3 of the OECD Guidelines: the five comparability factors at 3.7, their practical weighting at 3.30-3.31, and the adjust-versus-exclude decision for every difference.
Read docThe CUP Provisions: When Direct Price Evidence Wins
The CUP provisions within Chapter 2 of the OECD Guidelines: internal and external CUP, commodity pricing, the comparability conditions and where no uncontrolled price exists.
Read docThe Resale Price Provisions: Distributors and Gross Margin
The resale price method within Chapter 2 of the OECD Guidelines: the reseller gross margin, when it fits distributors, and its link to tested party selection at 2.48.
Read docThe Comparable Profits and Cost-Based Provisions
The cost plus and comparable profits provisions within Chapter 2 of the OECD Guidelines: cost base design, the comparable mark-up, contract manufacturing and routine services.
Read docThe Profit Split Provisions: When Both Parties Are Non-Routine
The profit split provisions within Chapter 2 of the OECD Guidelines: contractual and residual splits, allocation keys, the data problem and the highly valuable intangible trigger.
Read docThe Uncontrolled Comparability Routes (UNGS and UNCR)
The uncontrolled goods or services and uncontrolled resale or conversion routes within Chapter 2 of the OECD Guidelines: the fallback references and when they work.
Read docOECD Intangibles: DEMPE, HTVI and Cost Contribution
Chapter 5 of the OECD Guidelines: DEMPE at 5.7-5.12, value creation and the residual, highly valuable intangibles, and cost contribution arrangements in practice.
Read docOECD Services: Benefit Test, LTVAS and the Safe-Harbour Zone
Chapter 6 of the OECD Guidelines: the benefit test for intra-group services, the LTVAS framework at 6.102-6.113, and the link to India Rule 10TD(2B) LVAS safe harbour.
Read docOECD Financial Transactions: Loans, Guarantees and Cash Pooling
Chapter 7 of the OECD Guidelines: interest benchmarking on intra-group loans, the genuine benefit test for guarantee fees at 7.13-7.19, and cash pooling.
Read docOECD Restructuring: Exit Charges, Location Savings and ThinCap
Chapter 9 of the OECD Guidelines: business rationale, exit charges, location savings and thin capitalisation, and how Indian practice picks up the same questions.
Read docBuilding the Range: IQR, Outliers and Significance
Chapter 11 of the OECD Guidelines: how benchmarking ranges are built, the interquartile range at 11.100-11.107, outlier treatment and the reliability of the result.
Read docOECD Documentation: The Three-Tier Architecture
Chapter 12 of the OECD Guidelines: the three-tier documentation architecture, what the local file, master file and CbCR each contain, and the India Rules 10D, 10E, 10DA, 10DB overlay.
Read docBrowse other sections
Go from guide to finished study
Quartyl applies the method, PLI and screening steps above automatically — with documented reasons for every exclusion.