The UN Primer on Transfer Pricing (the UN TP Primer) provides a brief introduction of the basic aspects of transfer pricing. It is intended for tax officials from relevant authorities, who are/will be involved in transfer pricing audits or technical advice and who have a very limited or no prior knowledge 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 Primer. The UN TP Primer also serves as a pre-requisite for participants in the UN Course on Transfer Pricing, with a view to providing them with some common basics and enabling them to fully benefit from the course.
The UN TP Primer provides a general overview of basic concepts of transfer pricing. It addresses the arm’s length principle and processes for analyzing transfer pricing issues, including functional and comparability analysis and transfer pricing methods. In addition, it covers documentation and access to information issues, as well as special issues and industries (for instance, intangibles, intra-group services, commodities and extraction industries). Finally, it features an introduction to transfer pricing audits, risk assessment and dispute avoidance and resolution mechanisms, as well as a practical case study to enable participants to gain confidence in applying the skills acquired during it. The UN TP Primer is delivered over the course of 2 days.