Subcommittee on Transfer Pricing—Practical Issues

Please note: For later documents see 2012 annual session page

• Status: Active
• Coordinator: Mr. Stig Sollund (Norway)
• Members
  • Mr. Mansor Hassan (Malaysia)
  • Mr. Julius Bamidele (Nigeria)
  • Mr. Harry Roodbeen (Netherlands)
  • Mr. Toshio Miyatake (Japan)
  • Mr. Kyung Geun Lee (Republic of Korea)
  • Mr. Monique Van Herksen (Netherlands)
  • Mr. Jolanda Schenk (Shell)
  • Mr. TP Ostwal (India)
  • Mr. Michael Kobetsky (UK)
  • Mr. Marcos Valadao (Brazil)
  • Mr. Nishana Gosai (South Africa)
  • Mr. Joseph Andrus (OECD)
  • Mr. Keiji Aoyama (Waseda University—Tokyo, Japan)
  • Mr. Giammarco Cottani (Italian revenue Agency—Rome, Italy)
  • Ms. Caraol Dunahoo (Baker and McKenzie LLP, USA)
  • Mr. Sanjay Kumar Mishra (India)
  • Ms. Caroline Silberztein (Baker and McKenzie LLP, France)
  • Mr. Shanwu Yuan (China)
• Mandate

The Subcommittee is mandated to develop a practical manual on transfer pricing, based on the following principles:

a) That it reflects the operation of Article 9 of the United Nations Model Convention, and the Arms Length Principle embodied in it, and is consistent with relevant Commentaries of the U.N. Model.

b) That it reflects the realities for developing countries, at their relevant stages of capacity development.

c) That special attention should be paid to the experience of other developing countries. That it draws upon the work being done in other fora. The aim of the Subcommittee shall be to present a complete draft manual for adoption to the 2011 annual session. An intermediate report showing substantial progress should be provided to the Committee in 2010.

• Creation: Fifth session of the Committee (2009)
• Activities:
  • Meetings
    • Kuala Lumpur, Malaysia, 16-17 June 2010: Report on Practical Manual on Transfer Pricing for Developing Countries
    • New Delhi, India, 2-4 February 2011: Working drafts of the Practical Manual on Transfer Pricing for Developing Countries
    • Tokyo, Japan, 28-29 October 2011: The participants focussed on refining the existing Chapters further, discussing dispute resolution issues with a view to the first drafting of the Dispute Resolution Chapter, giving first consideration to a draft Foreword to the Manual and incorporating some of the issues and examples discussed in the Special Meeting on Practical Transfer Pricing Issues for Developing Countries Held from 7 to 8 June 2011 in UN Headquarters New York and separately reported as Report on the informal meeting on practical transfer pricing issues for developing countries
    • Johannesburg, South Africa, 14-16 February 2012,
    • Beijing, China, June 2012.
  • Reports
    • Working Draft on Chapter 1: An Introduction to Transfer Pricing
    • Working Draft on Chapter 2: Business Framework
    • Working Draft on Chapter 2A: The Legal Environment
    • Working Draft on Chapter 3: Capability Building
    • Working Draft on Chapter 4: Traditional Methods
    • Working Draft on Chapter 5: Transactional Profit Methods
    • Working drafts of the Practical Manual on Transfer Pricing for Developing Countries
    • Practical Manual on Transfer Pricing for Developing Countries
• Output: The Practical Manual on Transfer Pricing for Developing Countries is expected in October 2012.