Nations Split on Fixes in UN Talks: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re easing into 2026 uncertainty—about tariffs, IRS staffing and enforcement, the OECD’s Pillar Two, and probably more. (Question: Will Pillar One and Amount B ever get back on the table?) But attention must be paid to the other global forum for tax and transfer pricing talk—the UN, where developing nations are pressing their case.

Negotiators at the United Nations are eyeing sweeping changes to transfer pricing rules as they design a tax treaty acceptable to developing economies. Big shifts would be pretty hard to pull off. ...