Yesterday the OECD released its Transfer Pricing Guidance on Financial Transactions. The sections of the report will be included as Chapter X in the OECD Transfer Pricing Guidelines. It is the first time that the OECD Transfer Pricing Guidelines will include extensive guidance on transfer pricing aspects of financial transactions. The report covers amongst others the following subjects:
- Determination when a purported loan should be regarded as a loan
- Treasury function (intra-group loans, cash pooling and hedging)
- Financial guarantees
- Captive insurance
- Risk-free and risk-adjusted rates of return
For more information on the changes regarding financial transactions we invite you to attend our QG Academy on financial transactions on February 19, 2020. Please subscribe here: https://lnkd.in/ehZkJ7c.
For the full report on financial transactions by the OECD, please click here: https://lnkd.in/gii9YCX.