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Arm’s length principle encounters the big fluffy hairy finance animal

Introduction With the recently published discussion draft of the OECD on Financial Transactions of 3th July 2018 a new chapter is added to the question whether the at arm’s length principle (“ALP”) applied for transfer pricing purposes will be str...
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Lithuania introduces new transfer pricing documentation guidelines

After becoming a member of the Organisation for Economic Cooperation and Development (“OECD”), Lithuania has updated its transfer pricing regulations in order to be aligned with the changes made to the OECD Transfer Pricing Guidelines after the Ba...
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Renewed ruling practice in the Netherlands, a first reaction

In the Netherlands, the ruling practice has been renewed. Quantera Global colleagues Richard Slimmen and Stefan Ubachs were interviewed by TaxLive to provide a first reaction. Comments made include: – the adjustments seem to be aimed at lett...
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Credit Ratings: what to consider?

  Introduction In the July published discussion draft, the OECD recognizes the use of credit ratings as an important tool to determine whether the conditions of intra-group loans are comparable to third party conditions. A credit rating serve...
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Intra-group loans; what to consider?

Introduction The in July published discussion draft of the OECD on financial transactions indicates that in making a transfer pricing analysis of intra-group loans, the same steps have to be taken as in transfer pricing analyses of other intercomp...
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