During its 14th session run on 3 - 6 April, the UN Committee of Experts on International Cooperation in Tax Matters released several documents including modifications to the UN Model Double Taxation Convention between Developed and Developing Countries and draft guidance on transfer pricing issues in Extractive industries.
The 'Proposed Base Erosion and Profit-Shifting Related Changes to the United Nations Model Double Taxation Convention between Developed and Developing Countries' document suggests changes that could be made to the text of the UN Model Tax Convention and its Commentaries to help address base erosion and profit shifting. Part A of this paper addresses possible changes relating to permanent establishments (Article 5), while Part B addresses possible changes to various articles and Commentaries to address the granting of treaty benefits in inappropriate circumstances.
This guidance note responds to that need and highlights some of the transfer pricing issues arising in the extractive industries. The Manual provides general guidance on technical aspects such as (i) the need for and how to conduct a comparability analysis; (ii) the respective available transfer pricing methods and how they operate; (iii) transfer pricing issues particular to intra-group services; (iv) transfer pricing considerations for intangible property; and more.
The other documents released can be found in the sources.
The 14th committee meeting will be followed by a UN ECOSOC special meeting on international cooperation in tax matters on April 7. The meeting will highlight the major accomplishments of the current membership of the Committee and will also discuss broader thematic issues in international tax cooperation.
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