‘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
Tag: Brazil
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
On the BRICS’ choice of diplomatic language at the OECD
I’ve just been reading through the 2010 update to the OECD model tax treaty [pdf] and in particular the different positions set out by non-OECD countries. This is where countries can put on record their objections to the model treaty, so that potential treaty partners know what they’re getting themselves into. I think the difference… Continue reading On the BRICS’ choice of diplomatic language at the OECD
Martin Hearson 