TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 8

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Peer reviews will continue to be carried out but at three different levels:

  1. 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 the monitoring process. For example, the best way to solve any problems emerging from such a review may be to analyse the issue in more detail by developing difficult case paradigms (see Section B.2 of this annex) or to develop practical examples for insertion in the Guidelines (see Section B.4 of this annex).
  2. The second level would be a “limited review” in that it would only look at the approach of a particular country or countries in relation to a specific and relatively narrow issue. The review would be carried out by two reviewers for each country and the level of input necessary would depend on the nature of the issue
  3. The third level would be a “full review” of a particular country which would be carried out according to the existing peer review guidelines referred to in paragraph 7 of this annex. A “full review” would therefore address directly the interpretation and application of the Guidelines in the particular member country.

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