United Nations
Draft toolkit on the art of tax treaty negotiation offers tips for developing countries
Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, writes about a draft toolkit for tax administrations on tax treaty negotiation published on June 29 by the Platform for Collaboration on Tax, which is a joint initiative of the IMF, OECD, UN, and World Bank Group (WBG) . . .
The United Nations’ effort to shape global transfer pricing policy
George L. Salis, Principal Economist and Tax Policy Advisor at Vertex, Inc., King of Prussia, Pennsylvania, discusses the United Nations’ international tax and transfer pricing work, including the outcome of the 19th Session of the UN Committee of Experts on International Cooperation in Tax Matters, held October 15-18 in Geneva . . .
The lack of transfer pricing comparables: selecting the appropriate box of apples in which to find bananas
Andrew Hickman, consultant and former OECD Transfer Pricing Unit Head, writes that the Platform for Collaboration on Tax’s draft toolkit on transfer pricing comparables would be improved if it minimized the prominence of geographic screening and maximized use of financial ratio screening.. . .
Comments released on tax guidance addressing offshore indirect asset transfers
18 comment letters – including letters from the governments of India and China — were released today responding to a draft “toolkit” designed to help developing countries address the taxation of offshore indirect transfers of assets, a practice used by some multinational corporations for tax avoidance. The guidance was prepared by “Platform for Collaboration on Tax,” a joint effort of the IMF, UN, OECD, and . . . .
UN committee weighing major updates to model tax treaty, other guidance
The UN Committee of Experts on International Cooperation in Tax Matters has released several documents outlining proposals that the committee will consider during its 14th session, which began today in New York. The papers reveal that . . .
Karanja to head OECD/UN Tax Inspectors Without Borders initiative
Kenyan tax official, James Karanja will lead the joint OECD/UN Tax Inspectors Without Borders (TIWB) initiative effective April 11, the OECD announced today. Karanja is assistant manager of the international tax . . .
UN transfer pricing guidance on intragroup services released, major update to manual planned
A new draft chapter on intragroup services for the United Nations Practical Manual on Transfer Pricing for Developing Countries (the UN transfer pricing manual), publicly released last week, differs from OECD guidance on the topic in a few areas, according to . . .
Key UN international tax committee elects leaders, sets new agenda
Davide Anghileri of the University of Lausanne, an MNE Tax contributing editor, discusses a meeting of the UN Committee of Experts on International Cooperation in Tax Matters, held in Geneva 17– 20 October, where new committee co-chairs were elected and subcommittee assignments were set, including assignments for a new subcommittee on the digitization of the economy . . .
Transfer pricing comparables “toolkit” reflects realities of developing nations, UN official says
A new “toolkit” which considers how developing nations can address a lack of comparables in transfer pricing, released jointly by the UN, OECD, IMF, and World Bank Group last June, reaffirms that the arm’s length approach can work for all nations but is also an imperfect, “not scientifically pure,” document, a UN official said July 18. Michael Lennard . . .
The UN transfer pricing manual’s new chapter on financial transactions: the details
Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, offer a detailed analysis of the UN Committee of Experts on International Cooperation in Tax Matters’ April 8 a draft chapter on financial transactions, proposed as an update to the UN Practical Manual on Transfer Pricing for Developing Countries . . .
New ‘toolkit’ addresses lack of transfer pricing comparables
The “Platform for Collaboration on Tax” – a joint initiative of the IMF, OECD, UN, and the World Bank – today published the final version of a toolkit designed to provide developing . . .
UN tax committee to consider major updates to transfer pricing manual, model tax treaty
The UN Committee of Experts on International Cooperation in Tax Matters (Committee) has released several reports in advance of its annual meeting, slated for October 11–14 in New York, revealing that significant changes to the UN transfer pricing manual and model tax convention are . . .