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The following is a transcription of a text found on the following website:

Deloitte | Transfer Pricing Alert | OECD | Transfer Pricing | Tax ...The JWG was disbanded earlier this year; the transfer pricing issues were .... with the economic and commercial reality of parties dealing at arm's length. ...
www.deloitte.com/.../fe42d87d79ffd110VgnVCM100000ba42f00aRC... -

Issues Note 4 – Recognition of Actual Transactions Undertaken
The fourth Issues Note discusses important notions regarding the exceptional circumstances in which a tax administration may consider not recognizing a transaction or structure adopted by a taxpayer, based on an analysis of the existing guidance at paragraphs 1.36-1.41 of the TP Guidelines and of the relationship between these paragraphs and other parts of the TP Guidelines.
• Depending on the circumstances and on the countries involved, domestic anti-abuse rules, such as CFC rules, might be applicable, but such domestic rules and their relationship with tax treaties are not within the scope of this project. Paragraphs 1.36-1.41 of the TP Guidelines are limited to the recognition of transactions for purposes of making transfer pricing adjustments covered by Article 9 of the OECD Model Tax Convention. They do not provide any guidance as to a country’s ability to characterize transactions differently under other aspects of its domestic law.
• Paragraphs 1.36-1.41 apply when there is a dispute about the fundamental nature of the transaction being examined. When there is no dispute about the nature of the transaction – and hence, no recognition issue – these paragraphs do not restrict a tax administration’s ability to adjust the price or other conditions of a controlled transaction to conform to the arm’s length standard.
• When paragraphs 1.36-1.41 do apply, Article 9 would allow an adjustment of conditions to reflect those the parties would have attained had the transaction been structured in accordance with the economic and "commercial reality" of parties dealing at arm's length. In doing so, the objective should be to arrive at a characterization or structure that comports as closely as possible to the facts of the case.
• Nonrecognition of transactions is not the norm, but an exception to the general principle that a tax administration’s examination of a controlled transaction ordinarily should be based on the transaction actually undertaken by the associated enterprises as it has been structured by them, using the methods applied by the taxpayer insofar as they are consistent with the TP Guidelines. The OECD considers that apparent non-arm’s length behavior should be dealt with, to the extent possible, on the basis of pricing adjustments, rather than by not recognizing transactions. In some situations, however, it may not be possible to arrive at an appropriate transfer price in the circumstances of the case.

Hope this helps.
In my 21st year of translating almost exclusively for Mexico City based member firms of big 4 and 2nd tier CPA firms, as well as other financial entities.