Subcommittee on Article 9 (Associated Enterprises): Transfer Pricing
Established: 20 October 2017
Coordinators: Ingela Willfors (Sweden)
Stig Sollund (Norway)
Participants in the Subcommittee:
Rajat Bansal (India)
Mitsuhiro Honda (Japan)
George Omondi Obell (Kenya)
Christoph Schelling (Switzerland)
Jose Ignacio Troya Gonzalez (Ecuador)
Sing Yuan Yong (Singapore)
Joe Andrus (Consultant)
Melinda Brown (International Organization/OECD)
Hafiz Choudhury (Business)
Sanya Gbonjubola (Nigeria)
Stefan Greil (Germany)
Andrew Hickman (Consultant)
Michael Kobetsky (Academia)
Michael McDonald (Business)
Toshio Miyatake (Business)
Emily Muyaa (NGO/IBFD)
TP Ostwal (Business)
Carlos Perez-Gomez (Business)
Raffaele Petruzzi (Academia)
Jolanda Schenk (Business)
Caroline Silberztein (Business)
Marcos Valadao (Academia)
Monique Van Herksen (Business)
Xiaoyue Wang (Business)
Ying Zhang (China)
Mandate
The Subcommittee is mandated to review and update the United Nations Practical Manual on Transfer Pricing for Developing Countries, based on the following principles:
- That it reflects the operation of Article 9 of the United Nations Model Convention, and the Arm’s Length Principle embodied in it, and is consistent with relevant Commentaries of the U.N. Model;
- That it reflects the realities for, and the needs of, developing countries, at their relevant stages of capacity development;
- That special attention should be paid to the experience of developing countries, and the issues and options of most practical relevance to them; and
- That it draws upon the work being done in other fora.
The Subcommittee shall give due consideration to the outcome of the OECD/G20 Action Plan on Base Erosion and Profit Shifting as concerns transfer pricing. The manual shall reflect the special situation of least developed economies.
The Subcommittee shall report on its progress at the sessions of the Committee and provide its final updated draft Manual for discussion and adoption no later than the 22nd session in 2021 and preferably in 2020.