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1. TPG2022 Chapter II paragraph 2.9 Moreover, MNE groups retain the freedom to apply methods not described in these Guidelines (hereafter “other methods”) to establish prices provided those prices satisfy the arm’s...
2. TPG2022 Chapter VI paragraph 6.198 In a transfer pricing analysis where the most appropriate transfer pricing method is the resale price method, the cost-plus method, or the transactional net margin method,...
3. TPG2022 Chapter II paragraph 2.3 Traditional transaction methods are regarded as the most direct means of establishing whether conditions in the commercial and financial relations between associated enterprises are arm’s length....
4. TPG2022 Chapter III paragraph 3.8 The review of the controlled transaction(s) under examination aims at identifying the relevant factors that will influence the selection of the tested party (where needed), the...
5. TPG2022 Chapter V paragraph 5.38 In order to simplify compliance burdens on taxpayers, tax administrations may determine, as long as the operating conditions remain unchanged, that the searches in databases for...
6. TPG2022 Chapter II paragraph 2.32 It may be appropriate to give more weight to other attributes of comparability discussed in Chapter I (i.e. functions performed, economic circumstances, etc.) when the profit...
7. TPG2022 Chapter III paragraph 3.57 It may also be the case that, while every effort has been made to exclude points that have a lesser degree of comparability, what is arrived...
8. TPG2022 Chapter III paragraph 3.5 In practice, this process is not a linear one. Steps 5 to 7 in particular might need to be carried out repeatedly until a satisfactory conclusion...