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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Annex II to OECD Chapter II · TPG 2022

Profit split.

A walkthrough of the 16 case studies in Annex II to Chapter II of the OECD Transfer Pricing Guidelines (2022 edition), illustrating when and how to apply the transactional profit split method.

Teaching summary. This walkthrough is a paraphrase of the OECD examples for learning purposes. For any binding interpretation, consult the OECD Transfer Pricing Guidelines themselves.

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Compare notes on profit-split cases

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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