Compare the United Nations Transfer Pricing Manual and OECD Transfer Pricing guidelines? What are the major differences?
Sample solution
Dante Alighieri played a critical role in the literature world through his poem Divine Comedy that was written in the 14th century. The poem contains Inferno, Purgatorio, and Paradiso. The Inferno is a description of the nine circles of torment that are found on the earth. It depicts the realms of the people that have gone against the spiritual values and who, instead, have chosen bestial appetite, violence, or fraud and malice. The nine circles of hell are limbo, lust, gluttony, greed and wrath. Others are heresy, violence, fraud, and treachery. The purpose of this paper is to examine the Dante’s Inferno in the perspective of its portrayal of God’s image and the justification of hell.
In this epic poem, God is portrayed as a super being guilty of multiple weaknesses including being egotistic, unjust, and hypocritical. Dante, in this poem, depicts God as being more human than divine by challenging God’s omnipotence. Additionally, the manner in which Dante describes Hell is in full contradiction to the morals of God as written in the Bible. When god arranges Hell to flatter Himself, He commits egotism, a sin that is common among human beings (Cheney, 2016). The weakness is depicted in Limbo and on the Gate of Hell where, for instance, God sends those who do not worship Him to Hell. This implies that failure to worship Him is a sin.
God is also depicted as lacking justice in His actions thus removing the godly image. The injustice is portrayed by the manner in which the sodomites and opportunists are treated. The opportunists are subjected to banner chasing in their lives after death followed by being stung by insects and maggots. They are known to having done neither good nor bad during their lifetimes and, therefore, justice could have demanded that they be granted a neutral punishment having lived a neutral life. The sodomites are also punished unfairly by God when Brunetto Lattini is condemned to hell despite being a good leader (Babor, T. F., McGovern, T., & Robaina, K. (2017). While he commited sodomy, God chooses to ignore all the other good deeds that Brunetto did.
Finally, God is also portrayed as being hypocritical in His actions, a sin that further diminishes His godliness and makes Him more human. A case in point is when God condemns the sin of egotism and goes ahead to commit it repeatedly. Proverbs 29:23 states that “arrogance will bring your downfall, but if you are humble, you will be respected.” When Slattery condemns Dante’s human state as being weak, doubtful, and limited, he is proving God’s hypocrisy because He is also human (Verdicchio, 2015). The actions of God in Hell as portrayed by Dante are inconsistent with the Biblical literature. Both Dante and God are prone to making mistakes, something common among human beings thus making God more human.
To wrap it up, Dante portrays God is more human since He commits the same sins that humans commit: egotism, hypocrisy, and injustice. Hell is justified as being a destination for victims of the mistakes committed by God. The Hell is presented as being a totally different place as compared to what is written about it in the Bible. As a result, reading through the text gives an image of God who is prone to the very mistakes common to humans thus ripping Him off His lofty status of divine and, instead, making Him a mere human. Whether or not Dante did it intentionally is subject to debate but one thing is clear in the poem: the misconstrued notion of God is revealed to future generations.
References
Babor, T. F., McGovern, T., & Robaina, K. (2017). Dante’s inferno: Seven deadly sins in scientific publishing and how to avoid them. Addiction Science: A Guide for the Perplexed, 267.
Cheney, L. D. G. (2016). Illustrations for Dante’s Inferno: A Comparative Study of Sandro Botticelli, Giovanni Stradano, and Federico Zuccaro. Cultural and Religious Studies, 4(8), 487.
Verdicchio, M. (2015). Irony and Desire in Dante’s” Inferno” 27. Italica, 285-297.
Sample Answer
Sample Answer
The Differences Between the United Nations Transfer Pricing Manual and OECD Transfer Pricing Guidelines
Introduction
Transfer pricing refers to the pricing of goods, services, and intellectual property transferred between related entities within multinational enterprises (MNEs). It is a critical aspect of international taxation, aiming to ensure that transactions between related parties are conducted at arm’s length. To provide guidance on this complex issue, both the United Nations and the Organization for Economic Cooperation and Development (OECD) have developed transfer pricing guidelines. This essay aims to compare the United Nations Transfer Pricing Manual and the OECD Transfer Pricing Guidelines, highlighting their major differences.
United Nations Transfer Pricing Manual
The United Nations Transfer Pricing Manual is a comprehensive document that offers guidance on transfer pricing for developing countries. It was developed by the United Nations Committee of Experts on International Cooperation in Tax Matters, with the goal of providing a practical approach to transfer pricing issues. Here are some key features of the UN Transfer Pricing Manual:
Broad Perspective: The UN Transfer Pricing Manual takes into account the specific challenges faced by developing countries. It emphasizes the need for transfer pricing rules that promote sustainable development and protect the tax base of these nations.
Emphasis on Comparable Uncontrolled Price Method: The manual places particular emphasis on the Comparable Uncontrolled Price (CUP) method, which compares prices charged in controlled transactions with prices charged in uncontrolled transactions.
Focus on Extractive Industries: Given the importance of extractive industries in many developing countries, the manual provides specific guidance on transfer pricing issues related to these sectors.
Transfer Pricing for Intangibles: The UN Transfer Pricing Manual recognizes the significant role of intangible assets in modern business models. It provides guidance on determining arm’s length prices for the transfer of intangibles between related parties.
OECD Transfer Pricing Guidelines
The OECD Transfer Pricing Guidelines are widely recognized as the international standard for transfer pricing. They provide guidance on the application of the arm’s length principle, which requires that transfer prices between related parties be set as if they were unrelated parties. Here are some key features of the OECD Transfer Pricing Guidelines:
Global Consistency: The OECD Transfer Pricing Guidelines aim to achieve consistency in transfer pricing practices across different jurisdictions. They provide a common framework for determining transfer prices, reducing the risk of double taxation and disputes between countries.
Emphasis on Economic Substance: The guidelines focus on the economic substance of transactions rather than their legal form. They consider the functions performed, risks assumed, and assets employed by related parties when determining transfer prices.
Use of Multiple Methods: The OECD Transfer Pricing Guidelines recognize that different transfer pricing methods may be appropriate depending on the circumstances. They provide guidance on the selection and application of various methods, including the Comparable Uncontrolled Price (CUP) method, the Resale Price Method (RPM), the Cost Plus Method (CPM), and others.
Transfer Pricing Documentation: The guidelines emphasize the importance of maintaining detailed transfer pricing documentation to support the arm’s length nature of related party transactions. This documentation includes functional analysis, economic analysis, and comparability analysis.
Major Differences
While both the United Nations Transfer Pricing Manual and the OECD Transfer Pricing Guidelines offer valuable guidance on transfer pricing, there are several key differences between them:
Focus: The UN Transfer Pricing Manual primarily targets the specific challenges faced by developing countries, whereas the OECD Transfer Pricing Guidelines aim for a global perspective and consistency across jurisdictions.
Emphasis on Comparable Uncontrolled Price Method: The UN Transfer Pricing Manual places greater emphasis on the CUP method, while the OECD Transfer Pricing Guidelines recognize the need for flexibility and consider multiple methods.
Treatment of Intangibles: The UN Transfer Pricing Manual provides specific guidance on transfer pricing for intangibles, acknowledging their significance in modern business models. The OECD Transfer Pricing Guidelines also address intangibles but offer more detailed guidance.
Transfer Pricing Documentation: While both documents emphasize the importance of maintaining transfer pricing documentation, the OECD Transfer Pricing Guidelines provide more specific guidelines on the content and format of documentation.
Conclusion
In conclusion, the United Nations Transfer Pricing Manual and the OECD Transfer Pricing Guidelines both provide valuable guidance on transfer pricing. While the UN manual focuses on the challenges faced by developing countries, the OECD guidelines aim for global consistency. These documents differ in their emphasis on transfer pricing methods, treatment of intangibles, and guidance on transfer pricing documentation. Understanding these differences is crucial for tax authorities, multinational enterprises, and practitioners involved in transfer pricing issues.
