TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 11

Posted on | By OECD
Category: OECD Transfer Pricing Guidelines (2022), TPG2022 Annex to the OECD TPG – Monitoring procedures and involvement of business
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The first issue is the procedure to be used and the responsibility assigned for identifying the difficult case paradigms, focusing on issues and situations where the Guidelines may provide no or inadequate guidance or where member countries might be interpreting the Guidelines differently and therefore presenting obstacles to an internationally consistent application of the Guidelines. Member countries can identify areas where, in their view, the Guidelines might not address or adequately address a particular issue.

Related Guidelines

TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 10 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...
TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 8 Peer reviews will continue to be carried out but at three different levels: The first level would be an “issue review ”, which would look at the approach taken by all member countries to a particular issue of widespread significance. Ideally, the review should link up with other aspects of...
TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 2 To summarise, the main purpose of the monitoring is to examine how far member countries’ legislation, regulations and administrative practices are consistent with the Guidelines and to identify areas where the Guidelines may require amendments or additions. The monitoring should not only lead to identification of problematic issues, but also...
TPG2022 Chapter IV paragraph 4.163 Concerns have also been expressed that, because of the nature of the APA procedure, it will interest taxpayers with a good voluntary compliance history. Experience in some countries has shown that, most often, taxpayers which would be interested in APAs are very large corporations which would be audited on a...
TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 1 In July 1995, the OECD Council approved for publication the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“the Guidelines”), submitted by the Committee on Fiscal Affairs (“the Committee”). At the same time, the OECD Council endorsed the Committee’s recommendation that the Guidelines be reviewed and up-dated periodically as...
TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 13 Individual countries would take responsibility at meetings of Working Party No. 6 for leading discussions of the difficult case paradigms and of problematic areas that can be illustrated with practical examples....
TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 16 The foregoing monitoring procedures will parallel the development of additional hypothetical examples to be added to the Guidelines. The examples are not intended to develop new principles or to cover new issues but rather to assist in interpreting principles and in addressing difficult issues already discussed in the Guidelines. To...
TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 17 It is not intended that the OECD should intervene in the resolution of transfer pricing disputes between a taxpayer and a tax administration. The monitoring process is not intended to be a form of arbitration and so taxpayers will not be able to present individual cases for resolution by the...
TPG2022 Chapter VII paragraph 7.62 Subject to the provisions of paragraph 7.55, the charge for services to any member of the electing MNE group shall be the sum of (i) the costs incurred by another group member in providing services specifically to the member under the second step as detailed in paragraph 7.57, plus the...
TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 23 The aim of this element in the monitoring process is to keep the member countries informed about developments in each others’ countries. There are usually well established ways at the national level by which the business community can make an input into any developments in the transfer pricing legislation, regulations...