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Transfer Pricing Documentation Requirements: OECD Guidelines vs. 6662 US Regulations

The transfer pricing regulations in the OECD guidelines constitute the international standard that OECD member countries have agreed should be used in analyzing transfer pricing issues between multinational enterprises and tax administrations. The OECD provides the guidance for both taxpayers and tax authorities. Many countries, however, have their own transfer pricing regulations, which while consistent with OECD guidelines, for the most part, can also have quite unique aspects.

This article compares the transfer pricing documentation requirements included in the OECD Guidelines with the 10 principal documents of the US regulations under the ยง 1.6662-6, identifying the convergence and divergence areas among those.