Subcommittee on Transfer Pricing
ESTABLISHED: 31st Session - October 2025
Mandate
The Subcommittee is mandated to:
- propose updates to the 2021 UN Transfer Pricing Manual;
- develop guidance on transfer pricing in specific sectors/industries;
- develop guidance on unilateral Advance Pricing Agreements/Arrangements; and
- liaise with the UN Model Subcommittee and the Subcommittee on the Digitalized and Globalized Economy on possible work by the Committee on profit attribution to permanent establishments.
This work shall be based on the following principles:
- That the work reflects the current version of the United Nations Model Tax Convention and its commentaries;
- That the work pays special attention to the experience of developing countries and reflects their realities and priorities at their relevant stages of capacity development, particularly in terms of availability of comparability data.
The Subcommittee shall identify linkages with the other Committee’s workstreams in its proposed work plan and, throughout its work, shall liaise with other relevant Subcommittees as appropriate to ensure coherence across the Committee’s outputs.
The Subcommittee will develop a proposed work plan setting out the scope of the update to the UN Manual, development of industry/sectoral guidance and development of guidance on unilateral Advance Pricing Agreements/ Arrangements by the Thirty-second Session (March 2026).
The Subcommittee will provide an initial report on possible work by the Committee on profit attribution to permanent establishments no later than the Thirty-third Session (October 2026).
The Subcommittee will make recommendations on the content of the update to the UN Transfer Pricing Manual no later than the Thirty-seventh Session (October 2028).
The Subcommittee will report to the Committee at each session.
In taking forward its work, the Subcommittee shall consult broadly with Member State Observers, academia, international and regional organizations, civil society, and industry stakeholders.
CO-COORDINATORS:
- Mathew Gbonjubola (Committee Member)
- Trude Steinnes Sønvisen (Committee Member)
- Wanda Montero Cuello (Committee Member)
PARTICIPANTS IN THE SUBCOMMITTEE:
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FOCAL POINT:
- Ilka Ritter - Economic Affairs Officer, Financing for Sustainable Development Office, DESA