TPG2022 Chapter II paragraph 2.174

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Category: OECD Transfer Pricing Guidelines (2022), TPG 2022 Chapter II: Transfer Pricing Methods | Tag: , ,
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Where comparable uncontrolled transactions of sufficient reliability are lacking to support the division of the relevant profits, consideration should be given to internal data, which may provide a reliable means of establishing or testing the arm’s length nature of the division of profits. The types of such internal data that are relevant will depend on the facts and circumstances of the case and should satisfy the conditions outlined in this section and in particular in paragraphs 2.147–2.148 and 2.166. They will frequently be extracted from the taxpayers’ cost accounting or financial accounting.

Related Guidelines

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