The changes in this edition of the Manual include:
- A revised format and a rearrangement of some parts of the Manual for clarity and ease of understanding, including a reorganization into four parts as follows:
- Part A relates to transfer pricing in a global environment;
- Part B contains guidance on design principles and policy considerations; this Part covers the substantive guidance on the arm’s length principle, with Chapter B.1. providing an overview, while Chapters B.2. to B.7. provide detailed discussion on the key topics. Chapter B.8. then demonstrates how some countries have established a legal framework to apply these principles;
- Part C addresses practical implementation of a transfer pricing regime in developing countries; and
- Part D contains country practices, similarly to Chapter 10 of the previous edition of the Manual. A new statement of Mexican country practices is included and other statements are updated;
- A new chapter on intra-group services;
- A new chapter on cost contribution arrangements;
- A new chapter on the treatment of intangibles;
- Significant updating of other chapters; and
- An index to make the contents more easily accessible
