Updates

UN Committee approved Transfer Pricing Manual Updates

Approved documents include:

1. Revised Chapter B.2 on comparability: Revisions were designed to provide consistency between UN TP Manual and the Platform for Collaboration on Tax’s comparability toolkit.

2. Revised Chapter B.5: On group synergies, which includes additional guidance on centralized procurement functions.

3. Approved Chapter B.9.4: On financial transactions dealing with guarantees.

4. Revised Chapter C.1: Which merges the main content of former B.8 on “General Legal Environment” and former Chapter C.1. on “Establishing and Updating Transfer Pricing Regimes”.

Further, following proposed changes to TP Manual were considered by the Committee of Experts at the meeting:

1. Revision of Part A: Transfer Pricing in a Global Environment to reflect, in particular, the nature and impact of new business models in a digitalized environment;

2. Revision of Chapter B.1: Introduction, to improve focus and avoid unnecessary overlaps and repetitions;

3. Revisions to Chapter B.4.2.7: Relationship Between Transfer Pricing and Customs Valuation; additional targeted and focused guidance on centralized sales functions; new financial transactions examples; and

4. A revised chapter on dispute avoidance and resolution.

The approved and pending chapters of the transfer pricing manual are available at below link:

https://www.un.org/development/desa/financing/sites/www.un.org.development.desa.financing/files/2020-05/CRP14%20-%20Transfer%20Pricing%20Manual%20Combined.pdf