The OECD has released the 2022 edition of its Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The 2022 edition includes the revised guidance on the application of the transactional profit method and the guidance for tax administrations on the application of the approach to hard-to-value intangibles agreed in 2018, as well as the new transfer pricing guidance on financial transactions approved in 2020. Consistency changes have also been made to the guideline…