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The 2021 UN Transfer Pricing Manual
A Step in the Right Direction
In April 2021, the UN released the third version of its Practical Manual on Transfer Pricing for Developing Countries. This article discusses its structure, contents, and highlights a few important changes in greater detail. Observations are also made regarding some similarities and divergences with the OECD guidelines. Finally, the article also focuses on the importance of the UN Manual and its distinguishing features.
1. Background
In 2009, the Committee of Experts on International Cooperation in Tax Matters (“the committee”) formed a sub-committee on transfer pricing to draft the United Nations Practical Manual on Transfer Pricing for Developing Countries (“Manual”). The first edition of the Manual was printed in 2013. Four years later in 2017, the second edition of the Manual was already out. The second edition was structurally different and comprehensive with additional detailed guidance on specific transactions and arrangements with numerous practical examples.
Keeping up with its tradition of revising the Manual every four years, the UN once again updated the Manual in 2021 (“2021 Manual”). The sub-committee that drafted the 2021 Manual was formed in 2017 at the 15th session of...