TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 5

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 monitoring process will be carried out through four related projects: 1. peer reviews of member country practices; 2. identification and analysis of difficult case paradigms; 3. review of changes in legislation, regulations, and administrative practices; and 4. development of examples. Each of these is discussed below.

Related Guidelines

TPG2022 Chapter II Annex I paragraph 1[See Chapter II, Part III, Section B of these Guidelines for general guidance on the application of the transactional net margin method. The assumptions about arm’s length arrangements in the following examples are intended for illustrative purposes only and should not be taken as prescribing adjustments and arm’s length arrangements...
TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 9To improve the effectiveness of the peer review process it is essential that the reviews are undertaken selectively and concentrate on the areas of greatest difficulty in applying the Guidelines. The final decision to undertake any of the three types of review will be made by the full Working Party...
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TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 10A 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...
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TPG2022 Chapter VI Annex I example 926. The facts in this example are the same as in Example 8, except as follows: Under the contract between Primair and Company S, Company S is now obligated to develop and execute the marketing plan for country Y without detailed control of specific elements of the plan by Primair....