About this project

This project provides a walkthrough of the examples contained in the OECD TP Guidelines. The aim is to facilitate the common understanding of TP principles by practitioners and tax administrations.

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OECD Chapter IX · TPG 2022

Business restructurings.

A walkthrough of eight curated examples distilled from the prose of Chapter IX of the OECD Transfer Pricing Guidelines (2022 edition). Chapter IX contains no formal numbered examples, so each one here is authorial and anchored to specific paragraphs.

Teaching summary. These examples are authorial paraphrases that distil specific paragraphs of Chapter IX for learning purposes. For any binding interpretation, consult the OECD Transfer Pricing Guidelines themselves.

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Compare notes on restructurings

If any of these examples raised a question, an edge case, or a different reading from how you'd apply it in practice, I'd like to hear. Message me on LinkedIn or get in touch by email — happy to compare notes.

Connect on LinkedIn ✉ Email aleks@inrange.nl

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