Taxpayers in developing markets can find it difficult to find reliable comparables to benchmark their transfer pricing. However, the UN Practical Manual on Transfer Pricing for Developing Countries demonstrates why detailed comparable transaction data is required by tax administrations in developing countries, when compared with guidance given by the OECD to member countries.
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Belt and Road Initiative countries face tax incentive conundrums due to pillar two, but relatively few countries would seek to scrap the project, ITR has heard