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The 2017 Update of the United Nations Practical Manual on Transfer Pricing for Developing Countries
The United Nations (‘UN’) Subcommittee on Article 9 (Associated Enterprises) – Transfer Pricing (“Subcommittee”) has recently worked on an update of the UN Practical Manual on Transfer Pricing for Developing Countries (“Manual”), which was officially presented on , at the UN Economic and Social Council (ECOSOC) meeting in New York. The work on the update of the first edition of the Manual, which was released in 2013, started at the 11th session of the UN Committee of Experts on International Cooperation in Tax Matters (“Committee”) in Geneva on 19–23 October 2015. After that session, the Subcommittee met three times to discuss the updates to the Manual before presenting them at the 12th session of the Committee in Geneva on 11–14 October 2016.
1. Changes in the New Manual
In general, the new Manual consists of some re-ordering of the chapters as well as some new chapters. Moreover, updates to the chapter on “Country Practices” have been made.
In details, the following changes have been implemented:
The format of the Manual, as well as its structure, has been rearranged to ensure more clarity and ease of understanding. To this end, the Manual has been re-organized in the fol...