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2. UN Practical Manual on Transfer Pricing for Developing Countries2. UN Practical Manual on Transfer Pricing for Developing Countries
UN Practical Manual on Transfer Pricing for Developing Countries - China
10.2. China Country Practices
Bridging the gap – applying the arm’s length principle in developing countries
10.2.1. Introduction
10.2.1. 1., The OECD transfer pricing guidelines have been the gold standard for tax administrations and taxpayers to apply the arms length principle for the valuation, for tax purposes, of cross‐border transactions between related parties for much of the period since the original version was first issued in 1995. As the world economy becomes increasingly globalised, transfer pricing is an issue faced not only by developed countries, but is increasingly a critical matter for developing countries. Such nations face a set of unique issues that have not been addressed, or at least not sufficiently or practically addressed by the OECD Guidelines. Therefore, while much of the OECD guidelines may still be applicable to developing countries, the UN Transfer Pricing Manual should put a special focus on offering practical solutions to issues faced by developing countries.
10.2.1.2. China started looking into transfer pricing issues since the late 1990s. While the early focus of transfer pricing investigations was mostly on tangible goods transactions, it has since been expanded into a range of other transactions, and in particular, those involving intangibles and services. As a developing country, China faces a number of difficult challenges, to many of which ready answers have not been found from the OECD guidelines. These include a lack of appropriate comparables, quantification and allocation of location specific advantages, and identification and valuation of intangibles. The UN Transfer Pricing Manual must address these common issues for it to be useful to developing countries.
10.2.1.3. we now highlight 2 challenging issues faced by the developing countries, and share China’s practical experience in dealing with these issues.
10.2.2. The challenge of a lack of
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