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 II · TPG 2022

Transfer pricing methods.

A walkthrough of the examples on the CUP, resale price, cost plus and transactional net margin methods in Chapter II of the OECD Transfer Pricing Guidelines (2022 edition), and the three illustrations in its Annex I. The profit split examples in Annex II have their own page.

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 method selection

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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