The Financing for Development Office (FfDO) of UN-DESA organized, in cooperation with the African Tax Administration Forum (ATAF), a 5-day UN Workshop on Transfer Pricing – Administrative Aspects and Recent Developments with the participation of representatives from developing countries in Africa.
The Workshop, drawing on the United Nations Practical Manual on Transfer Pricing for Developing Countries (the Manual), aimed to provide participants with additional insight on transfer pricing issues, and was intended as the third UN-ATAF joint event following the introduction presented during the UN Primer on Transfer Pricing (Lusaka, Zambia, 17-18 June 2015) and the comprehensive overview provided during the UN Workshop on Transfer Pricing – Comparability and Transfer Pricing Methods (Antananarivo, Madagascar, 14-17 November 2016).
The Workshop focused in particular on the administrative aspects of transfer pricing, including documentation, audits and dispute resolution; it also provided an overview of the new chapters of the updated UN Practical Manual on Transfer Pricing for developing countries, and an analysis of the Toolkit for Addressing Difficulties in Accessing Comparables Data for Transfer Pricing Analyses, developed by the Platform for Collaboration on Tax (a joint initiative by the United Nations, OECD, IMF and World Bank). In addition, it featured several examples and reference to developing countries practices and experiences. Finally, the workshop featured comprehensive case studies to enable participants to gain confidence in applying the skills acquired.
The Workshop was facilitated by renowned experts in the area of transfer pricing, and simultaneously translated into French. Participants were requested to actively contribute to the discussion, also drawing from their experience in transfer pricing issues.
- Introduction / Introduction
- Documentation / Documentation
- Audit and Risk Assessment / Audit et évaluation des risques
- Presentation on the Comparability Toolkit / Discussion de la Boîte à outils sur la comparabilité
- Comparability Toolkit / Boîte à outils sur la comparabilité
- Intragroup Services Transacations / Services intragroupe
- Intangibles / Actifs incorporels
- Case example – Intangibles and Services / Exemple – Actifs incorporels et services
- Cost Contribution Arrangements / Accords de répartition des couts
- Establishing Transfer Pricing Capability / Développer les capacités de prix de transfert
- Dispute Avoidance and Resolution / Prévention et résolution de différends
- Case example APA / Exemple APP
- Case example MAP / Exemple PAM