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Transfer Pricing KnowledgeRegulation Reference

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.

Regulation Reference3 Sept 2026

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.

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Regulation Reference3 Sept 2026

OECD 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.

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Regulation Reference3 Sept 2026

OECD 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.

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Regulation Reference3 Sept 2026

The 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.

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Regulation Reference3 Sept 2026

The 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.

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Regulation Reference3 Sept 2026

The 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.

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Regulation Reference3 Sept 2026

The 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.

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Regulation Reference3 Sept 2026

The 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.

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Regulation Reference3 Sept 2026

OECD 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.

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Regulation Reference3 Sept 2026

OECD 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.

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Regulation Reference3 Sept 2026

OECD 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.

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Regulation Reference3 Sept 2026

OECD 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.

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Regulation Reference3 Sept 2026

Building 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.

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Regulation Reference3 Sept 2026

OECD 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.

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