The UN updated TP guide

On April 27, 2021, a new version of https://bit.ly/3nX0Myc

of the UN TP Guide for Developing Countries was published.

The new version of the Guide still consists of four parts, but with certain changes.

🔸 Part A contains an overview of transnational companies, the features of their functioning, as well as the management of TP processes within such structures.

🔸 Part B describes the concept of the "arm's length" principle, comparability analysis, transfer pricing methods, and recommendations on pricing policies for certain types of transactions and contracts. In Part B of the Guide, the authors added a new section for financial transactions. Part B was also supplemented by provisions on central procurement functions and updated recommendations for the application of the profit-sharing method and comparability analysis.

🔸 Part C deals with the implementation of TP rules in developing countries.

🔸 Part D describes the practice of applying transfer pricing rules in selected countries, in particular Brazil, China, Mexico, South Africa, Kenya, and India.

It should be noted that Ukraine is a member of the UN, therefore the use of the Guide in the justification of transfer pricing can be positively perceived by both tax authorities and courts.