“Transfer pricing” refers to the pricing of transactions by component parts of a multinational group, as a normal part of their business models. However, these prices can sometimes be manipulated (“transfer mis-pricing”) so that, for example, profits are booked to low-tax or no-tax countries and expenses are booked to higher taxing countries, where they can be deducted. Tackling mis-pricing is a key part of current efforts against tax avoidance and evasion. The United Nations Practical Manual on Transfer Pricing for Developing Countries helps developing countries to achieve fair outcomes in this notoriously complex, information- and skill- dependent area of taxation. The approach set out in the Manual adheres to the “arm’s length” principle, comparing actual pricing with what such pricing would be in a competitive market. The UN Tax Committee works now on a new version of this widely used Manual, including new content on financial transactions and profit splits. The tax capacity building activities of UNDESA are directly linked to the Committee’s work in this and many other areas. This two-day regional workshop for tax officials from Africa will feature a comprehensive review of the administrative aspects related to transfer pricing, at intermediate level, including documentation, audits and risk assessment, especially in industries relevant to the region, including extractives and telecommunications. The workshop will also feature presentations of the proposed new chapters of the Manual.

Related documents

Manual (2017)