TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 16

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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 ensure that they are of practical value and avoid being overly prescriptive the examples will be short, based on stated facts and relatively straightforward so that their scope is not so confined that the guidance they provide is of narrow and limited application. The examples will fall into two broad categories. The first will consist of illustrations of the application of the methods and approaches described in the Guidelines. The second set of examples will be designed to aid in the selection of a suitable transfer pricing method or methods. Although hypothetical, the examples will draw on the practical experiences of tax administrations and taxpayers in applying the arm’s length principle under the Guidelines, and will contribute to the establishing of good practices.

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