UN Proposes Public Transfer Pricing Database in Tax Treaty Talks

A United Nations committee is gauging support for including mechanisms for resolving transfer pricing disputes in a global tax treaty under negotiation.

The treaty’s top negotiators proposed creating a UN-managed transfer pricing database or pooling country resources to buy commercially available databases. The measures would level the playing field between multinationals and the tax administrations of developing countries during transfer pricing disputes, the negotiators said.

“Taxpayers hold detailed knowledge of their own operations, often leaving tax administrations at a disadvantage during audits, negotiations or litigation,” the negotiators said in a note.

The committee released the proposals ahead of meetings ...