UN transfer pricing guidance for developing countries could increase burdens on multinationals

Washington National Tax Services

The United Nations on October 2 released an updated version of its Practical Manual on Transfer Pricing for Developing Countries.  On October 15, the UN Committee of Experts on International Cooperation in Tax Matters (the Subcommittee) approved the current unedited version of the UN Transfer Pricing Manual and approved a one-month period for receiving nonsubstantive comments.

As the Manual recognizes, implementation of additional transfer pricing regimes could lead to increasing documentation and regulatory burdens for taxpayers.  While the Manual may foresee continued complexity and regulatory requirements in the transfer pricing arena, the continued acceptance of the arm’s-length standard and the resultant avoidance of double taxation should be somewhat reassuring to taxpayers.

The latest version of the Manual includes six updated chapters; two new chapters regarding establishing government transfer pricing programs in developing countries and initiating transfer pricing audits; and four short, single-country perspectives that explain the transfer pricing practices of Brazil, China, India, and South Africa.

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