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United Nations Practical Manual on Transfer Pricing

The United Nations has released a publication titled “Practical Manual on Transfer Pricing”. The Manual contains valuable discussion on a number of important topics. For instance, there is a detailed discussion on the types of transfer methods available (such as CUP, TNMM etc) and their respective merits and demerits. Practical examples and case studies have also been given to explain in what circumstances a particular method is suitable. There is also detailed discussion on how comparables should be selected and how a comparability analysis should be conducted. There is also detailed discussion on the transfer pricing implications of marketing intangibles (trade marks, technical know-how etc) which becomes very relevant in the light of L.G.Electronics vs. ACIT 140 ITD 41 (SB). There is also a write-up on the law & practices being followed in India and other countries.

The Manual will prove invaluable for all professionals seeking in-depth understanding of transfer pricing concepts.


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  1. […]   United Nations Handbook On Double Tax Avoidance Treaties (2.5 MiB) See also: UN Model Double Taxation Convention 2011 (March 2012 Release) & United Nations Practical Manual on Transfer Pricing […]

  2. […] that such data cannot be called for or insisted upon from the taxpayer. This is supported by the United Nation’s Practical Manual on Transfer Pricing for Developing Countries which stated that a foreign entity (a foreign AE) could also be taken as a tested party for […]

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