‘Country Practices’. The title of Chapter 10 of the new United Nations Practical Manual on Transfer Pricing [pdf] doesn’t exactly set the pulse racing. But as I noted in my blog on the manual as a whole, this document is politically very significant. It’s probably the only detailed description of Brazil, China, India and South… Continue reading UN transfer pricing manual: what Brazil, India and China do differently
Category: The politics of international tax
The United Nations Practical Manual on Transfer Pricing: a bluffer’s guide
Last week saw the official launch of a 495-page document by the United Nations tax committee, its new Practical Manual on Transfer Pricing for Developing Countries [pdf]. The final product has been four years in the making and is an impressive, introductory-level guide to transfer pricing. So definitely worth dipping in and out of if… Continue reading The United Nations Practical Manual on Transfer Pricing: a bluffer’s guide
Treating tax incentives like illegitimate debt
I’m at the United Nations tax committee, which yesterday hosted a day’s discussion on taxing the mining, oil and gas sectors. Quite a bit of the discussion dwelt on the stability clauses that are often built into contracts between the governments of developing countries and extractive industry companies making investments. In general these clauses insulate… Continue reading Treating tax incentives like illegitimate debt
Why FATCA might be good for developing countries
Recently I wrote a post explaining that I feel cautious about the burden that compliance with an automatic tax information exchange standard would place on developing countries. Since then a new paper by Itai Grinberg has popped up called Emerging Countries and the Taxation of Offshore Accounts. This amused me. I encountered Grinberg a couple… Continue reading Why FATCA might be good for developing countries
Death and taxes and zombies
One of the highlights of last weekend’s Critical Tax Theory Conference was a paper on an issue that I had previously never considered, but which could have major implications for developing as well as developed countries. Definitely something for development NGOs to consider. Here’s the abstract: The U.S. stands on the precipice of a financial… Continue reading Death and taxes and zombies
Developing countries and the social nature of international tax
Over the weekend I was lucky enough to be able to attend the 16th annual Critical Tax Theory conference, held this year at the Hastings College of Law in San Francisco. It was a chance to get some really useful feedback from a group who are very focused on using empirical evidence to answer questions… Continue reading Developing countries and the social nature of international tax
Martin Hearson 