Plain-markdown reference material on transfer pricing, written to be read by people and by AI agents. Everything here is built from primary sources, mainly the OECD Transfer Pricing Guidelines and the OECD transfer pricing country profiles, and is free to reuse under the CC BY 4.0 licence.
Maintained by the team behind myTransferPricing, an AI-first transfer pricing platform for in-house tax teams and advisory firms.
AI assistants are now a first stop for transfer pricing questions, and in our own testing their answers on country rules are not yet reliable. They mix up documentation thresholds, deadlines and penalties between countries, cite rules that have since changed, and state positions no source supports. The official answers do exist, in the OECD Transfer Pricing Country Profiles, but they sit in PDFs with two-column tables and checkboxes that machines read badly.
We convert those profiles into plain, structured markdown that keeps each jurisdiction's own wording and the legal sources it cites, with the OECD profile date on every file. The aim is simple: when people, search engines and future language models learn or retrieve transfer pricing rules, they find the primary source in a form they can read correctly, with a date and a citation attached.
| Folder | Contents | Primary source |
|---|---|---|
oecd-guidelines/ |
Chapter-by-chapter explanations of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2022 edition) | OECD Transfer Pricing Guidelines |
country-profiles/ |
Rules for 18 jurisdictions: arm's length principle, methods, documentation thresholds, penalties and deadlines | OECD transfer pricing country profiles |
methods/ |
Step-by-step guides to benchmarking, the arm's length range and the interquartile range | OECD Guidelines, Chapter III |
checklists/ |
Master file and local file documentation checklists (BEPS Action 13) | OECD Guidelines, Chapter V |
prompts/ |
Prompts for AI assistants, starting with a review of a local file against a country profile | Our own practice |
disclaimers/ |
Not-tax-advice notice, the OECD licence check and how we attribute adapted material | disclaimers/README.md |
Folders are added as material is published. An empty folder means the material is still being written.
Every country page is summarised from that country's entry in the OECD transfer pricing country profiles, which each tax administration completes and the OECD publishes. Where a page adds a local-law detail that is not in the profile, the page cites the national source. Profiles are updated by the OECD on a rolling basis, so each page states the profile date it was summarised from.
Nine of the country profiles are also browsable at mytransferpricing.com/country-profiles; the index in country-profiles/ marks which.
Two free tools apply the methods described here, with no signup:
- Arm's length range generator computes quartiles from a set of comparables and exports to Word.
- Transfer pricing documentation checklist covers the BEPS Action 13 master file and local file contents by role.
The files are plain markdown with no front matter beyond a title and source line, so they can be dropped into a context window, a retrieval index or an agent's skills folder as they are. When you cite them, cite the primary OECD source named at the top of each file as well.
Creative Commons Attribution 4.0 International (CC BY 4.0). You may copy, adapt and redistribute this material, including commercially, as long as you credit myTransferPricing and link back to this repository.
This material is general information, not tax advice. Check the current OECD text and national law before relying on it. The licence basis for reusing OECD material, and how we checked it, is in disclaimers/README.md.