Category: Blogs

When entering into intercompany transactions, Transfer Pricing documentation is always important. The intercompany prices must be at arm’s length, and be substantiated. The compliance challenges do not end here. During the BEPS-project the OECD st...

On the 11th of February 2020 the OECD released its new transfer pricing guidance on financial transactions which will be included in the OECD Transfer Pricing Guidelines. This guidance is a follow-up of the public discussion draft of July 3, 2018 ...

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 w...

Transfer Pricing Audit Framework 2019 The Malaysian Inland Revenue Board (“MIRB”) released the Transfer Pricing (“TP”) Audit Framework 2019 (“TPAF 2019”) to replace the 2013 version (“TPAF 2013”) effective 15 December 2019. Highlighted below are s...

Last Friday the OECD has mentioned in its webcast that the final guidance on financial transactions will be released on the 11th of February. The initial non-consensus draft was published 3 July 2018 and we expect that the final guidance will, amo...

This news item has been posted with thanks to our strategic alliance partner Oliver Treidler (TP&C GmbH, Berlin). Transfer Pricing is becoming more and more a balance between international OECD guidelines and local interpretation and additiona...

In this post-BEPS age more and more countries are implementing Transfer Pricing documentation regulations. This substantially increases the compliance burden for both small and large MNEs. Full-on transfer pricing compliance with all local regulat...

Often, we are asked to test an intercompany loan to see whether the interest rate is at arm’s length. However, at times we are asked to help with the setting up of an intercompany loan. Where testing is focussed on finding comparables in which the...