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UN tax committee to update to key transfer pricing manual for developing countries

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By Julie Martin, Editor, MNE Tax

The next edition of the United Nations Practical Manual on Transfer Pricing for Developing Countries will include a new chapter on financial transactions, substantial revisions current guidance on the transactional profit-split method, and new material on centralized procurement functions, according to a newly-released UN document that summarizes the most recent meeting of the Committee of Experts on International Cooperation in Tax Matters.

According to the UN document, members of a subcommittee responsible for updating the UN transfer pricing manual said at the October 16-19 Committee of Experts meeting that the new financial transactions chapter will cover intragroup loans and financial guarantees.

The chapter will address the importance of corporate financing decisions among multinational groups and how those decisions could lead to tax base erosion, said subcommittee member, Monique van Herksen.

The draft chapter should be available for review at the next Committee of Experts meeting, van Herksen said.

Ingela Willfors, who co-coordinates the subcommittee responsible for updating the transfer pricing manual with Stig Sollund, said that the UN transfer pricing manual’s guidance on the transactional profit split method will be updated to better align the manual with work done by the OECD-led “Inclusive Framework on BEPS.”

The revised provisions will include practical examples and will explain when and how to use the profit-split method, Willfors said.

Sollund said that the UN transfer pricing subcommittee also intends to provide broad and updated guidance on centralized procurement and sales functions.

The subcommittee will also update UN manual chapters that cover transfer pricing in a global community, the general legal environment, audits and risk assessment, and establishing transfer pricing capability in developing countries.

The manual’s chapter on comparability analysis will also be updated to further address how to handle the lack of comparables, subcommittee members said.Further, the transfer pricing subcommittee is discussing updates to part D of the UN transfer pricing manual on country practices and is considering the relationship between transfer pricing and customs valuation, the UN document reports.

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Dimension Transfer Pricing International Taxation South African Tax Law
Jurisdictional audience Global audience, covers all jurisdictions Global audience, covers all jurisdictions South Africa specific, relevant to SADC region
Ideal for TP managers, advisors, in-house tax teams, analysts moving into TP Advisors and managers dealing with cross-border rules, treaties, planning Practitioners working with the SA Income Tax Act, cases, compliance
Core focus Methods, comparables, DEMPE, documentation, audits, dispute defence Treaties, source vs residence, anti-avoidance, PE, relief from double tax Statutory interpretation, case law, assessments, objections, local practice
Primary tools OECD TP Guidelines, UN Manual, BEPS Actions 8–10, 13, case law OECD and UN Models, MLI, BEPS 1.0 and 2.0, domestic rules, cases Income Tax Act, SARS practice notes, Tax Administration Act, SA cases
Assessment style Case-based assignments, file reviews, short written defences Problem questions, treaty interpretation, position papers Problem questions, statutory analysis, case commentary
Typical outcomes Build defensible TP files and strategies, improve audit readiness Design cross-border structures within rules, mitigate double tax Apply SA tax law accurately, manage reviews and disputes
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Dimension Conducting a Transfer Pricing Trial Effectively Managing Tax Teams Indirect Taxation Tax Risk Management
Jurisdictional audience Global audience Global audience Global audience, with local adaptation Global audience
Ideal for In-house tax, TP managers, litigators, advisors preparing for audits, ADR, trial Heads of tax, managers, team leads, controllers, emerging leaders VAT, GST, customs, finance managers, AP, AR, compliance specialists Tax managers, risk officers, controllers, advisors building governance
Core focus Case theory, evidence files, expert reports, witness prep, courtroom strategy Operating models, KPIs, workflows, stakeholder management, coaching VAT design, place of supply, input credits, exemptions, WHT interactions Risk identification, controls, documentation, audit readiness, dispute playbooks
Delivery mode Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study
Duration 16 weeks, part-time 16 weeks, part-time 16 weeks, part-time 16 weeks, part-time
Outcomes Confident litigation preparation and defence for TP disputes Stronger execution, clear roles, measurable team performance Reduced VAT errors, better cash flow, fewer surprises at audit Structured governance, fewer findings, faster dispute resolution
Prerequisites TP fundamentals recommended Supervisory experience helpful Basic VAT knowledge helpful General tax experience helpful
Pathway Progress to PG Certificate in Transfer Pricing Progress to Mechanics of Leading Tax Teams, PG Certificate (leadership) Progress to PG programmes, International Tax or SA Tax Law Progress to PG Certificate in International Taxation or Transfer Pricing
Assessment End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected