TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 22

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The difficult case paradigms are intended to illustrate issues and situations where the Guidelines provide no or inadequate guidance. Practical examples when complete will be inserted into the Guidelines to provide illustrations of particular principles. There is a clear role for the business community in assisting in the development of paradigms or examples by contributing the practical experience of their members. The Working Party will ask for comments on both the difficult case paradigms and the practical examples at regular stages in their development. BIAC may also initiate paradigms or examples, provided the caveats in paragraph 17 of this annex are followed so that there can be no question of the process being used to resolve a particular transfer pricing case.

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