The draft of a Practical Manual on Transfer Pricing for Developing Countries (the “Draft”) was the main focus of the Eighth session of the UN Committee of Experts on International Co-operation in Tax Matters held on 15-19 October 2012 in Geneva.
The Draft is published on the UN website. Even though it is not the final version of this document, it reflects the problems which developing countries face and which companies incorporated in such countries have to solve in relation to transfer pricing.
It is clear that the UN followed the Organisation for Economic Co-operation and Development which adopted Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations in June 1995.
Once adopted, this document will become a recommended standard to be adhered by domestic laws of developing countries.
[Draft of the Practical Manual on Transfer Pricing for Developing Countries is available on UN website here]