UN Releases TP Manual For Developing Countries

During UN meetings last week, the UN’s Committee of Experts on International Cooperation in Tax Matters released an updated version of the 'United Nations Practical Manual on Transfer Pricing for Developing Countries,' the MNE Tax reported.

Background: UN Committee

The Committee of Experts on International Cooperation in Tax Matters as a subsidiary body of the Economic and Social Council is responsible for keeping under review and update, as necessary, the United Nations Model Double Taxation Convention between Developed and Developing Countries and the Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries.

Practical Manual on Transfer Pricing for Developing Countries

The second edition of the United Nations Practical Manual on Transfer Pricing for Developing Countries draws upon the experience of the first edition (2013) including feedback on that version, but also reflects developments in the area of transfer pricing since that time. The changes in this edition of the Manual include:

  • A revised format and a rearrangement of some parts of the Manual for clarity and ease of understanding, including a reorganization into four parts as follows:
    • Part A relates to transfer pricing in a global environment;
    • Part B contains guidance on design principles and policy considerations;
    • Part C addresses practical implementation of a transfer pricing regime in developing countries; and
    • Part D contains country practices, similarly to Chapter 10 of the previous edition of the Manual. A new statement of Mexican country practices is included and other statements are updated;
  • A new chapter on intra-group services;
  • A new chapter on cost contribution arrangements;
  • A new chapter on the treatment of intangibles;
  • Significant updating of other chapters; and
  • An index to make the contents more easily accessible.

Sources: MNE Tax, UN, Practical Manual on TP
 

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