Transfer Pricing and The United Nations

Learning CentreTransfer Pricing and The United Nations

Transfer Pricing and The United Nations 

The UN issued the “UN Practical Manual on Transfer Pricing for Developing Countries” in 2013, and updated it in 2021. The UN Model Double Taxation Convention between Developed and Developing Countries was also updated in 2021. It should be noted that the UN Model Convention generally favors the retention of greater host country taxing rights, and is utilized more strongly in developing countries.

The United Nations established the Committee of Experts on International Cooperation in Tax Matters to provide international oversight of and policy guidance on international tax matters.One of its functions is to examine transfer pricing practices, not just in terms of mutual cooperation and assistance in the collection of debts but also concerning protocols for the mutual agreement procedure, treaty shopping and treaty abuses, the interaction of tax, trade, and investment, for financial taxation, and for equity market development.

A multilateral instrument is currently being used to implement Article 12B, Income from Automatic Digital Services, of the United Nations Model Convention. This would involve the use of a multilateral instrument similar to that developed by the OECD to implement BEPS changes to the OECD Model Convention.