United Nations Practical Manual on Transfer Pricing for Developing Countries 2017

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The United Nations Practical Manual on Transfer Pricing for Developing Countries (2017) is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular. Such guidance not only assists policy makers and administrators in dealing with complex transfer pricing issues that are often manipulated to avoid paying tax, but will also assist taxpayers in their dealings with tax administrations.Without an effective response to transfer pricing issues, profits earned in one jurisdiction might appear to be shifted to another jurisdiction. This may have the net effect of minimizing tax revenues in a country where economic activity of the MNE really takes place, and therefore the ability to finance a country’s development. The first edition of the Manual (2013) was highly influential in providing very practical guidance to help countries address complex transfer pricing issues and in giving expression to emerging developing country approaches, and this edition not only updates that guidance in a way that reflects developing country realities and priorities but addresses some issues of great importance, such as transfer pricing of intangible property such as intellectual property, in much more detail.


UN/Department of Economic and Social Affairs
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