Transcription of Chapter 5 Transfer Pricing Methods - United Nations
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Chapter 5 Transfer Pricing Methods - United Nations
Agenda Item 5 Working Draft Chapter 5 Transfer Pricing Methods [This paper is based on a paper prepared by Members of the UN Tax Committee s Subcommittee on Practical Transfer Pricing Issues, but includes some Secretariat drafting and suggestions not yet considered by them the Secretariat takes responsibility for any relevant errors and omissions. Formerly, Methods were dealt with in Chapters 4 and 5, which are now combined hence the reference, on a temporary basis, to Parts 5A and 5B of this paper]. [Table of Contents to be added] Chapter 5A Traditional Methods 1. Introduction This part of the Chapter describes several Transfer Pricing Methods that can be used to determine an arm s length price and it describes how to apply these Methods in practice.
Page 2 of 65 and taxpayers in UN Member Countries to gain experience with the application of transfer pricing methods while seeking ways to get more conformity with the OECD TP Guidelines.
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