TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 24

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 input from the BIAC will be discussed at the regular joint meetings between the BIAC and the Working Party.

Related Guidelines

TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 22The 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...
TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 13Individual 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 23The 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...
TPG2022 Chapter X paragraph 10.1The purpose of this Chapter is to provide guidance for determining whether the conditions of certain financial transactions between associated enterprises are consistent with the arm’s length principle....
TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 4In line with the Council’s Recommendation, there will be a role for the business community in the monitoring and this role is set out in Section C....
TPG2022 Chapter X paragraph 10.38In any case, the reliability of results is generally improved to the extent comparable borrowers pursue similar business strategies to the tested borrower involved in an intra-group transaction....
TPG2022 Chapter IV Annex II paragraph 60Many countries prefer to be fully involved in the process as soon as it commences and wish to work closely with the other competent authorities. Other countries prefer to confine their involvement to reviewing and commenting upon the MAP APA proposals as they near completion. However, the involvement of all...
OECD COVID-19 TPG paragraph 110The COVID-19 pandemic also presents practical difficulties for tax administrations and taxpayers currently negotiating APAs. Potential challenges may arise for a number of reasons including restrictions on domestic and international travel; enforced or voluntary working from home; or additional resource pressures as a result of efforts to manage responses to...
TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 19In contributing to the OECD role of monitoring the implementation of the Guidelines, the business community would be encouraged to take particular note of the guidance given at paragraph 17 of this annex. It should therefore focus on issues that give rise to either theoretical or practical difficulties and not...
OECD COVID-19 TPG paragraph 111Despite these potential challenges, the value of achieving advanced certainty and effective dispute prevention through APAs remains compelling. A number of tax administrations and taxpayers have identified a variety of ways to adapt working practices in order to overcome any practical impediments to working APAs. Tax administrations and tax payers...