TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 10

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A key aspect of monitoring will be to identify and then to analyse difficult fact patterns and problem areas which may be illustrated by practical examples and which present obstacles to an internationally consistent application of the transfer pricing methods set out in the Guidelines. Monitoring will also include areas where the Guidelines appear to offer no or inadequate guidance to tax authorities or taxpayers. All member countries will be actively involved in this process and recognise that resources will be required to ensure its success. The business community will also be involved in the monitoring (see Section C of this annex).

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