Global Transfer Pricing Resources
Transfer pricing news, updates, briefings, alerts, and insights are ideal sources for staying up to date on the latest developments and gaining new insights into all sorts of transfer pricing topics.
The only problem is that there are many online transfer pricing resources, and they are all screaming for your attention. It is estimated that there are more than 440 million blogs worldwide, and about 2 million blog posts are written daily. Luckily, not all of them write about Transfer Pricing, but you get the idea, right?
So, which transfer pricing resources successfully provide the information you need, and how can you find them?
Below, we have provided an overview of global transfer pricing resources published by key players in the tax sector. The links provide access to their relevant resources page, which deals with that particular transfer pricing topic.
All resources are free and directly accessible (no registration or email drop required). If the information is behind a paywall or requires payment, this will be explicitly mentioned.
Country Transfer Pricing Guides
Most of the transfer pricing guides stated below include at least the following topics on a per-country level:
Recent developments, local law framework, relationship with OECD Transfer Pricing Guidelines, methods and comparables, transfer pricing documentation requirements and disclosure timelines, tax return filings, transfer pricing adjustments, intangibles, intragroup services, financing transactions, interest & penalties, permanent establishments, exit tax, recent court decisions, APAs, mutual agreement procedures.
- Deloitte - Transfer Pricing Guides: covering transfer pricing guides of 73+ countries worldwide.
- EY - Worldwide Transfer Pricing Reference Guides: a downloadable transfer pricing reference guide covering 121 jurisdictions. Updated on an annual basis.
- Grant Thornton - Global Transfer Pricing Guide: covering transfer pricing guides of 80+ countries worldwide.
- OECD - OECD Transfer Pricing Country Profiles: covering transfer pricing country profiles of 80+ countries. The country profiles focus on domestic legislation in each country regarding key transfer pricing principles. The jurisdictions themselves provide the information in each country profile based on questionnaires.
OECD Transfer Pricing Guidelines
The OECD’s work on transfer pricing aims to eliminate double taxation by applying the arm’s length principle as set out in the OECD Transfer Pricing Guidelines. The Guidelines provide the global standard for pricing related-party cross-border transactions, help prevent and eliminate tax disputes, and promote a level playing field for tax administrations and businesses.
The table below provides an overview of the key publications of the OECD.
OECD Transfer Pricing Reports Overview (1995–2025)
Key OECD transfer pricing publications with links to the official OECD pages.
| # | Year | Report Title / Edition | Main Focus / Contribution | Status in Current Framework |
|---|---|---|---|---|
| 1 | 1995 | OECD Transfer Pricing Guidelines (1st edition) | First consolidated global TP standard aligning with the Arm’s Length Principle (ALP). | Superseded; foundation of later editions. |
| 2 | 1996 | Intangibles & Services Report | Guidance on intragroup services and intangibles valuation. | Integrated into later Guidelines. |
| 3 | 1997 | Cost Contribution Arrangements (CCAs) | Defines shared development cost structures. | Incorporated as Chapter VIII. |
| 4 | 1999 | APAs under Mutual Agreement Procedures | Introduces bilateral/multilateral APA process guidance. | Annexed to Guidelines. |
| 5 | 2008 / 2010 | Attribution of Profits to Permanent Establishments (AOA) | “Authorized OECD Approach” (AOA) for PE profit attribution. | Companion document to TP Guidelines. |
| 6 | 2010 | Revised OECD TP Guidelines | Major overhaul — comparability, transactional profit methods, business restructurings (Ch. IX). | Superseded by later editions. |
| 7 | 2010 | Comparability & Profit Methods Report | Background to 2010 revision of Chapters I–III. | Integrated. |
| 8 | 2013 | Safe Harbour Guidance (Revised Section E) | Simplified approaches and risk reduction for SMEs. | Incorporated in 2017 edition. |
| 9 | 2014 | BEPS Action 13: Guidance on TP Documentation & CbCR | Introduces three-tiered documentation (Master / Local / CbCR). | Precursor to final BEPS report. |
| 10 | 2015 | BEPS Actions 8–10: Aligning TP Outcomes with Value Creation | Rewrites intangibles, risk & DEMPE analysis. | Embedded in 2017 Guidelines. |
| 11 | 2015 | BEPS Action 13: Final Report | Finalised CbCR standard & implementation. | Stand-alone; still valid. |
| 12 | 2017 | OECD TP Guidelines (2017 edition) | Incorporates BEPS Actions 8–10 & 13 changes. | Superseded by 2022 edition. |
| 13 | 2018 | Guidance on the Profit Split Method | Clarifies when and how to apply profit split. | Added to 2022 edition. |
| 14 | 2018 | Guidance on Hard-to-Value Intangibles (HTVI) | Arm’s-length pricing for uncertain IP valuations. | Added to 2022 edition. |
| 15 | 2020 | TP Guidance on Financial Transactions | Loans, cash-pooling, guarantees, hedging, capital structure. | Added as Chapter X in 2022 edition. |
| 16 | 2022 | OECD TP Guidelines (2022 edition) | Consolidated version including HTVI & financial transactions. | Current authoritative text. |
| 17 | 2024 | Pillar One – Amount B Report | Simplified baseline return for routine marketing/distribution activities. | Implementation from 2025. |
| 18 | 2025 | Consolidated Report on Amount B | Final consolidated guidance and practical refinements. | Latest OECD TP report. |
Source: OECD publications and official PDFs (1995–2025).
Transfer Pricing News & Newsletters
Keeping up with the constant flow of transfer pricing developments worldwide can be a challenge. The sources listed below keep you up to date with the latest relevant developments.
The sources below mainly cover global developments. For country-specific transfer pricing developments, we suggest taking a look at the "Country Transfer Pricing Guides" as listed above or visiting the local site of one of the Big 4 firms.
-
PwC
-
Tax Insights from Transfer Pricing: This regular newsletter provides alerts and analysis of major inter-company pricing issues and related developments from around the world.
- TP Talks: A global transfer pricing podcast series, where PwC professionals share perspectives on today's key transfer pricing developments around the world.
- TP Blog: A global transfer pricing blog series that provides in-depth insights and practical guidance on how to navigate the regulatory transfer pricing landscape.
-
Tax Insights from Transfer Pricing: This regular newsletter provides alerts and analysis of major inter-company pricing issues and related developments from around the world.
-
Deloitte
- Tax@hand: Deloitte's global tax news and insights platform, designed for tax professionals and executives, with a transfer pricing filter applied.
<< To be continued >>