On March 7, 2014, TEI submitted comments to the United Nations regarding the United Nations Practical Manual on Transfer Pricing for Developing Countries. TEI recommended, among other things, that the United Nations continue to support the arm’s length principle for transfer pricing purposes, respect contractual arrangements among members of a multi-national enterprise when those arrangements are consistent with their substance, and keep in place the current international tax system for determining ownership of intangible assets within a multi-national group.
TEI’s comments were prepared under the aegis of TEI’s European Direct Tax Committee, whose chair is Nick Hasenoehrl of Herbalife. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI’s comments.