The Manual is focused on transfer pricing in a global environment, while it provides guidance on design principles and policy considerations. It also addresses the practical implementation of a transfer pricing regime in developing countries and shares examples of country practices from developing countries, such as Brazil, China, India, Kenya, Mexico, and South Africa.
The United Nations (UN) has published the third edition of the UN Practical Manual on Transfer Pricing for Developing Countries.
The UN Practical Manual on Transfer Pricing for Developing Countries provides guidance on the policy and administrative aspects of undertaking a transfer pricing analysis. The guidance assists policy makers and administrators in dealing with complex transfer pricing issues, and it assists taxpayers in dealing with tax administrations.
The UN Manual is a signature product of the UN Committee of Experts on International Cooperation in Tax Matters. In its third edition, the UN Manual improves existing guidance and introduces new elements in response to some of the cutting-edge issues in transfer pricing. The Manual is focused on transfer pricing in a global environment, while it provides guidance on design principles and policy considerations. It also addresses the practical implementation of a transfer pricing regime in developing countries and shares examples of country practices from developing countries, such as Brazil, China, India, Kenya, Mexico, and South Africa.
The 2021 UN Manual brings a new chapter on financial transactions and additional guidance on group synergies and centralized procurement functions. It also includes revised guidance on profit splits and on how to establish transfer pricing capabilities within tax administrations.
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable at editor@transferpricingnews.com