The Commentary on Article 9 – The Changes and Their Significance and the Ongoing Work on the UN Transfer Pricing Manual

Journal
United Nations
Bulletin for International Taxation 2012 (Volume 66), No. 11
The authors, in this article, examine the limited changes to the Commentary on Article 9 of the UN Model (2011) and the significance of the differences with the Commentary on Article 9 of the OECD Model, together with a brief consideration of the proposed UN Transfer Pricing Manual.