In an October 24 letter, William J. Sample, Chair, Taxation Committee of the United States Council for International Business (USCIB) states that if adopted, the UN’s proposed modification to the commentary to Article 9 of the UN Model will lead to increased disputes and double taxation. Sample condemned the lack of input by stakeholders in the UN process and argues that is inappropriate for non-OECD countries that participated in OECD transfer pricing guideline negotiations and obtained concessions to “undercut” those negotiations by arguing elsewhere for positions that were rejected. USCIB
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