The UN Committee of Experts on International Cooperation in Tax Matters has released several reports that suggest changes to the UN’s transfer pricing manual for developing countries. Other reports addressing issues such as model tax treaty or mutual agreement procedure were released in advance of UNs annual meeting taking place in Geneva on October 11-14.
The Subcommittee said the manual could be improved by the proposed re-ordering together with the additions. The Manual would be more responsive to issues of current country concern and also more in tune with rapid developments in this area.
The changes of the model include:
During the 12th Session of the Committee of Experts, the Subcommittee on Transfer Pricing plans to bring the new proposed version of the Manual to this Committee’s attention for its approval, with a view to its being published and publicized in Spring 2017.
Some of the papers that were released as part of the agenda include: Revised Draft Article and Commentary for UN Model Tax Convention; Taxation of the extractive industries; Mutual agreement procedure; Application of treaty rules to hybrid entities; Article 12 (Royalties); Article 26 (Exchange of information); Proposed BEPS-related Changes to the United Nations Model; and Taxpayer rights in cross-border tax disputes.
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