BorderCrossings ... with Ernst & Young's transfer pricing and tax professionals
United Nations transfer pricing guidance: harmony or discord?
To help you stay informed and able to adapt to an increasingly uncertain and challenging global tax environment, Ernst & Young is pleased to bring you this fourteenth installment of BorderCrossings – our monthly webcast series devoted to transfer pricing and related tax issues. The second season of our BorderCrossings series continues this month with a discussion of the Transfer Pricing Manual currently being drafted by the subcommittee appointed by the United Nations Committee of Experts on International Cooperation in Tax Matters (the UN Committee of Experts).
United Nations Transfer Pricing Manual
The UN Committee of Experts released its updated UN Model Convention on 15 March. In addition to an updated Commentary to the existing Convention there are some updated or new Treaty articles put in place. In the background, there is also discussion on how to provide more guidance to developing countries with respect to the application of transfer pricing principles applicable under Article 9 of the Convention.
To accommodate developing country needs in this respect, the UN Committee of Experts has embarked on a project to draft a Transfer Pricing Manual. The Manual is intended to provide developing countries with an introduction to transfer pricing principles and methods and practical guidance on how these principles and methods can be implemented by a developing country’s tax authority. The webcast will address issues such as:
- The role of the Manual, in light of the existing OECD Transfer Pricing Guidelines
- The extent to which the Manual might differ from the OECD Guidelines in theory and in practice
- The timetable governing finalization of the Manual
During this live, interactive webcast, you will have the opportunity to ask questions through the website and the panelists will answer as many of your questions as time permits.
This program will be of interest to vice presidents/directors of tax/international tax/transfer pricing, directors of finance, CFOs, international tax managers and tax accountants looking for the latest practical information and planning ideas to support their global business initiatives. We hope you will be able to join us.
Kenneth Christman, Ernst & Young LLP (US), Transfer Pricing
Monique van Herksen, Ernst & Young Belastingadviseurs LLP, Transfer Pricing
Fred O’Riordan, Ernst & Young LLP (Canada), National Advisor, Tax Services
Save the date for the next BorderCrossings webcast:
1:00–2:15 p.m. EDT New York/Toronto; 10:00–11:15 a.m. PDT Los Angeles/Vancouver