The OECD Transfer Pricing Guidelines 2022 set out guidance on applying the arm's length principle of Article 9 of the OECD Model Tax Convention to transactions between associated enterprises. Chapters I to III cover the arm's length principle, transfer pricing methods and comparability analysis. Chapter IV addresses avoiding and resolving disputes through corresponding adjustments, the mutual agreement procedure, safe harbours and advance pricing arrangements. Chapter V sets out three-tiered documentation of master file, local file and Country-by-Country Report. Chapters VI to X deal with intangibles, intra-group services, cost contribution arrangements, business restructurings and financial transactions, supported by annexes of examples and the Council Recommendation.