TPG2017 Annex to OECD Transfer Pricing Guidelines paragraph 19

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In contributing to the OECD role of monitoring the implementation of the Guidelines, the business community would be encouraged to take particular note of the guidance given at paragraph 17 of this annex. It should therefore focus on issues that give rise to either theoretical or practical difficulties and not on specific and unresolved transfer pricing cases. However, it may be useful to illustrate a particular issue by reference to a hypothetical example. In constructing such an example, which could draw upon features taken from a number of real cases, care should be taken to ensure it remains hypothetical and does not resemble a current case, and that the features described should be restricted to the problematic issues concerned in order to avoid an impression of setting any general precedent for the resolution of an individual case.






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