TPG2022 Chapter IV Annex II paragraph 55

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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.

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