The UN Course on Transfer Pricing (the UN TP Course) is a training tool, developed by the Financing for Development Office (FfDO) in the area of transfer pricing, which is intended for tax officials from relevant authorities, who are responsible for and/or are involved in transfer pricing audits or technical advice and who have a basic understanding of transfer pricing issues. Tax officials in large taxpayers’ offices, as well as in offices responsible for special sectors, who normally deal with transfer pricing, might also benefit from the Course.
The UN TP Course aims at strengthening the capacity of developing countries in applying the “arm’s length principle” in taxing multinational companies utilizing the United Nations Practical Manual on Transfer Pricing for Developing Countries (UN TP Manual).
The UN TP Course was developed as a result of a unique collaborative engagement between a diversified group of authors and members of the Subcommittee on Transfer Pricing of the United Nations Committee of Experts on International Cooperation in Tax Matters comprising world-renowned experts in the field of transfer pricing, and FfDO.
The UN TP Course is delivered in regional setting over the period of 5 days. In addition to instruction provided by world-renowned experts and FfDO staff, regional experts are invited to provide practical insights and relevant examples from their country practices throughout the course. The UN TP Course provides an overview of transfer pricing principles and methodologies and deals with the main practical issues faced by developing countries in applying these principles and methodologies. The course comprises several examples and a comprehensive integrated case study to enable participants to gain confidence in applying the skills acquired. The course consists of 9 modules, corresponding to the chapters of the UN TP Manual, as follows:
- An introduction to transfer pricing;
- Business framework;
- The general legal environment;
- Establishing transfer pricing capability in developing countries;
- Comparability analysis;
- Transfer pricing methods;
- Documentation;
- Audits and risk assessment;
- Dispute avoidance and resolution.
The UN Couse is complemented by the UN Primer on Transfer Pricing, which is intended for officials with very limited or no experience in transfer pricing in order to bring them up to speed and allow them to fully benefit from the UN TP Course.