In reviewing the MAP APA proposal, the tax administrations may undertake whatever steps they deem appropriate in the circumstances to conduct the mutual agreement procedure. These include, but are not limited to: requests for further information deemed relevant to review and evaluate the taxpayer’s proposal, the carrying out of fieldwork (e.g. visits to taxpayer’s premises, interviews with staff, review of financial or managerial operations, etc.) and the engaging of necessary experts. Tax administrations may also have recourse to information collected from other sources, including information and data on comparable taxpayers.
TPG2022 Chapter IV Annex II paragraph 55
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By OECD
Category: OECD Transfer Pricing Guidelines (2022), TPG2022 Annex II to Chapter IV – Conduction of APA and MAP
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- 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...