UN's Draft Practical Manual On TP: India Chapter

The United Nations (UN) recently released eight draft chapters of its Practical Manual on Transfer Pricing for Developing Countries (the UN TP Manual or the Manual).

October 17, 2012 / 17:45 IST

The United Nations (UN) recently released eight draft chapters of its Practical Manual on Transfer Pricing for Developing Countries (the UN TP Manual or the Manual). Also, included in the Manual are a Foreword and a draft chapter (Chapter 10) containing country specific perspectives which explain the transfer pricing (TP) administrative practices prevalent in four countries, viz., Brazil, China, India (referred to as India chapter), and South Africa.

The Foreword to the Manual clarifies that Chapter 10 is different from the other chapters as it represents an outline of the particular countries’ administrative practices as described by representatives of those countries. Accordingly, as further stated in the Foreword, Chapter 10 does not reflect the official view of the UN.

The India chapter, which is a part of Chapter 10, primarily discusses some of the emerging transfer pricing issues in India as described by the Indian tax administration. Some of the India issues have been discussed in the UN TP Manual, while others have not yet been addressed at all in the Manual. An analysis thereof is provided in this alert by PwC.

first published: Oct 17, 2012 05:36 pm

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