Tuesday, 25 April 2017

UN updates its Practical Manual on Transfer Pricing for Developing Countries

On April 7, the UN released the second edition of its Practical Manual on Transfer Pricing for Developing Countries. Like its 2013 predecessor, this revised edition provides detailed guidance on application of the arm’s-length principle for developing countries, with the objective of addressing base erosion risks and issues, such as a lack of local comparable data to determine market prices. The revision serves as an update to incorporate aspects of the changes to the OECD Transfer Pricing Guidelines following the final papers of the OECD/G20 BEPS Project released in October 2015.

The initiative is intended as further endorsement of the arm’s-length principle as stipulated in Article 9 of both the UN Model Convention and OECD Model Tax Convention, as well as the OECD Transfer Pricing Guidelines. The Practical Manual is intended to strengthen the consistency of international tax rules and facilitate inclusion of developing countries. With the document presenting broad consensus among the members of the drafting Subcommittee, questions remain, however, on the cohesiveness of the approaches and long-term application of this revision, particularly in light of ongoing OECD initiatives.

Source & more info: PwC