The UN subcommittee drafting the practical manual on transfer pricing for developing countries said the document will be constantly updated and so, initially, it will not attempt to fully address the issue of intangibles but instead will wait for the results of the OECD project on the subject.
A Canadian taxpayer has made an advance pricing agreement (APA) request to the Mexican tax authorities and has made an unusual amount of information public.
Delegates at the UN’s Committee of Experts on International Cooperation in Tax Matters are voicing their concerns about the wording of the UN model double taxation convention relating to transfer pricing.
The UN Committee of Experts on International Cooperation in Tax Matters has come to an agitated approval of the commentary on article 9 of the OECD’s transfer pricing guidelines.
