Generally, the competent authorities would conduct simultaneous, independent reviews and evaluations of the taxpayer’s proposal, assisted in this task, where necessary, by transfer pricing, industry, or other specialists from elsewhere in their tax administration. However, it may be more efficient in appropriate cases to have some degree of joint fact finding. This could take a variety of forms ranging from an occasional joint fact finding meeting or site visit, to the preparation of a joint report by delegated caseworkers.
TPG2022 Chapter IV Annex II paragraph 58
Posted on | By OECD
Category: OECD Transfer Pricing Guidelines (2022), TPG2022 Annex II to Chapter IV – Conduction of APA and MAP
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