UN Updates Transfer Pricing Manual on Intragrup Services Finance

The UN Tax Committee established a new sub‑committee on 5 November 2025 to revise the UN Practical Manual on Transfer Pricing for Developing Countries (UN TP Manual). The sub‑committee is tasked with updating three specific chapters covering intragroup services, intragroup intangibles, and intragroup financial transactions.

The revision will focus on simplification through safe‑harbour rules and updated country chapters, and will provide clearer guidance on service types and benefit‑tests. Chapter 6 will address the growing practice of bundling intangibles by multinational enterprises by adding criteria for allocating profits from development, acquisition, enhancement, maintenance, protection and exploitation (DAEMPE) activities. Chapter 9 will give tax authorities practical tools to distinguish loans from equity contributions and will include sector‑specific guidance for telecom and tourism, which are prone to transfer‑pricing abuse.

These updates aim to improve tax certainty for multinational groups and assist developing‑country tax administrations in evaluating intragroup transactions, thereby strengthening tax bases. The new guidance on arm‑length profit attribution to permanent establishments will also respond to increased labor mobility and the rise of service‑providing permanent establishments.