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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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap