The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations are the global reference manual for how cross-border transactions between related parties should be priced for tax purposes. They are not law, but in practice they drive domestic legislation, audits, and court decisions in most countries.

OECD Pillar One – Amount B is a simplified, standardized transfer pricing regime for baseline marketing and distribution activities. It is designed to reduce disputes by replacing bespoke benchmarking with fixed returns.

Section 482 of the U.S. Internal Revenue Code and the accompanying Treasury Regulations are the U.S. transfer pricing rulebook. 

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IRC Section 482 authorizes the IRS to allocate income, deductions, credits, or allowances between related parties to prevent tax evasion and to clearly reflect income.

The OECD Transfer Pricing Country Profiles are jurisdiction-by-jurisdiction summaries showing how each country applies (or departs from) the OECD Transfer Pricing Guidelines in practice.

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They are not law, not guidance, and not safe harbours. They are a transparency and expectation-setting tool for taxpayers and tax authorities.