On 26 March 2025 the UN Tax Committee discussed their transfer pricing work. Since the previous session of the Committee, the Subcommittee on Transfer Pricing has gathered feedback from members on possible future workstreams that could be pursued by the next subcommittee that will begin work next year. There has also been discussion with the Subcommittee on Extractives Industries Taxation on areas where their work overlaps with transfer pricing issues.

An area identified for future work was intragroup financial transactions. Practical transfer pricing guidance could be developed on issues such as how to distinguish between equity and loans; country risk adjustments; and cash pooling.

Developing country tax administrations with limited resources may also experience problems with transfer pricing related to intangible assets; and the future subcommittee may make a contribution in this area. The bundling of different types of intangibles can present challenges and guidance could be helpful. Practical guidance on performing a development, acquisition, enhancement, maintenance, protection, and exploitation (DAEMPE) analysis of intangible assets would also be useful for developing country tax administrations.

Guidance in the area of transfer pricing of management services would be of assistance to tax administrations as these services are often a problem area for developing countries. Also, additional examples and descriptions could be developed for particular service categories. Another beneficial area for practical guidance would be on performing a benefit test.

Industry guidance has recently been released by the Tax Committee on the pharmaceutical industry and on agricultural products. Additional industry guidance could be valuable. and members of the Subcommittee suggested that these could include transfer pricing guidance for telecoms and for infrastructure development.

These are proposals for the next transfer pricing subcommittee. The workstreams pursued by the new subcommittee will be decided by its members, after the new subcommittee is established.