Ava Colocho
Transfer Pricing Senior Manager, CBIZ, USA

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Transfer Pricing Senior Manager with CBIZ based in Irvine, California.

Srinidhi Tuppal
Srinidhi Tuppal
Transfer Pricing Manager, CBIZ, USA

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Transfer Pricing Manager with CBIZ’s National Transfer Pricing Practice.

OECD Transfer Pricing Guidelines

July 20, 2022

CBIZ Transfer Pricing experts, Srinidhi Tuppal and Ava Colocho were recently invited to share their expertise with International Accountant magazine on the most recent developments from the OECD 2022 update and the impact that has globally on transfer pricing.

OECD and the policy impact

For any multinational business, the inclusive framework and the 15-point action plan will have already had a significant impact on any existing transfer pricing/tax planning strategy. The recent article by Srinidhi and Ava gives readers an overview of the progression of the policy that impacts transfer pricing and outlines the specific impact of the new 2022 updates compared to the 2017 policy.

OECD 2022 updates

There are three main updates to the policy;

  • Revision to the transactional profit split method
  • Revision to the hard-to-value-intangibles (HTVI)
  • Transfer pricing guidance on financial transactions

The three new reports were developed in 2017 and the 2022 update clarifies points made in these reports, specifically;

The appropriate application of the transactional profit split method

Ex-post outcomes as presumptive evidence about the appropriateness of the ex-ante pricing arrangements, aiming to reach equitable practice of application of adjustments, to improve consistency and reduce the risk of double taxation.

OECD 2022 update takeaways

MNE should update their transfer pricing policies to reflect the new OECD policies, testing the processes used to determine the unique and valuable contributions provided by the parties and
during the selection of an appropriate method. In addition, the risk of double taxation as a result of the updated HTVI policy is critical for effective tax planning.

To read the full article, click here