RoyaltyRange LATAM Lead contributes to new UN Practical Manual on Transfer Pricing for Developing Countries
Article – May 2021 | RoyaltyRange
We are proud to announce that Carlos Pérez Gómez Serrano (our LATAM Lead) was on the Subcommittee that reviewed and updated the United Nations Practical Manual on Transfer Pricing for Developing Countries for the third edition, which was released on April 27th 2021.
Carlos joined representatives from non-governmental organizations, the private sector and academia, as well as tax and policy officials, to review and update the Manual.
As well as leading RoyaltyRange’s business growth in the LATAM region, Carlos is an established transfer pricing expert.
He says: “The UN Transfer Pricing Practical Manual is a very valuable tool, not only for Tax Administrations, but also for taxpayers, as it is practicual and grounded on real life cases. For developing countries it is a “must”, as it also includes references to organization and experiencies of successful Transfer Pricing departments throughout the world.”
What is the United Nations Practical Manual on Transfer Pricing for Developing Countries?
The intention of the United Nations Practical Manual on Transfer Pricing for Developing Countries (2021) is to “contribute to a common understanding of how the arm’s length principle is to be applied in order to avoid double taxation and prevent or resolve transfer pricing disputes”.
It can be used by policymakers and tax administrations in developing countries to handle complicated transfer pricing issues.
What was the role of the Subcommittee?
The Subcommittee was tasked with updating the Manual to reflect developments in transfer pricing and administration since the second edition (2017).
The updates needed to reflect Article 9 of the UN Model Convention (and the relevant Commentaries) and pay special attention to the needs and realities of developing countries.
How is the third edition of the Manual different?
The third edition of the Manual contains new content on financial transactions, profit splits, centralized procurement functions, comparability issues and country practices.
It also has improved usability and practical relevance for developing countries.