Tax Cooperation Policy Brief 2, May 2018

Transfer Pricing: Concepts and Practices of the ‘Sixth Method’ in Transfer Pricing

Many developing countries are particularly concerned with problems of transfer pricing in the extractive industries, which are often significant components of their economies. Similar to other sectors, profit attribution may be highly dependent on the valuation of commodity exports. For this reason, a number of developing countries have adopted the ‘Sixth Method’, following the Argentine experience. This method aims to establish a clear and easily administered benchmark and avoid the need for subjective judgment and discretion.

However, even when the application of the Sixth Method is legislated for, and given Argentina’s extended experience dealing with commodity mis-invoicing, the data shows that such practices are still being employed by multinational companies.

This policy brief analyses the problem of the valuation of commodities, actual policy experience and the policy’s impact and the lessons learned.

This brief is part of the South Centre’s policy brief series focusing on tax policies and the  experiences in international tax cooperation of developing countries.

Efforts to reform international cooperation in tax matters are exhibiting a distinct acceleration.  The direction of change must recognize and incorporate innovations in developing country policies and approaches, otherwise the outcomes will obstruct practical paths to development.

The policy brief series is intended as a tool to assist in further dialogue on needed reforms.

*** The views contained in the policy briefs are personal to the authors and do not represent the institutional views of the South Centre or its Member States.

Download the tax cooperation policy brief below :

Concepts and Practices of the ‘Sixth Method’ in Transfer Pricing



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