miércoles, 28 de junio de 2017

United Nations updates transfer pricing manual on developing countries

On 7 April 2017, the UN Committee of Experts on International Cooperation in Tax Matters issued a second edition of its Practical Manual on Transfer Pricing for Developing Countries. Similar to the 2013 edition, the revised manual is designed to respond to developing countries’ needs for guidance on the policy and administrative aspects of applying a transfer pricing analysis to intercompany transactions of multinational enterprises (i.e. applying the arm’s length principle to such transactions).
Salient features of the revised version of the manual are as follows:

  • It closely reflects the content of the OECD BEPS report on actions 8-10 (now included in the OECD’s transfer pricing guidelines).
  • It includes updated guidance on transfer pricing documentation, as well as a discussion of the three-tiered approach to documentation, i.e. the master file, local file and country-by-country reporting.
  • A new section on transfer pricing methods describes the use of the “sixth method” (sometimes called the “commodity rule”) that relies on quoted prices of the commodities market to price commodity transactions between associated enterprises. The sixth method has been used in certain Latin American countries.
  • New chapters are added on intragroup services, cost contribution arrangements and intangibles.
  • The final section of the manual contains an outline of country-specific transfer pricing rules and experience (Brazil, China, India and South Africa (covered in the 2013 edition) and Mexico (newly added)). 

Source: Deloitte

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