Strategizing International Tax Best Practices – by Keith Brockman

The OECD recently published Transfer Pricing Guidance on Financial Transactions, an inclusive framework on BEPS Actions 4, 8-10.  This guidance takes into consideration comments received in the July 2018 discussion draft on financial transactions.

The guidance represent an update to the OECD Transfer Pricing Guidelines.  

This importance guidance presents guidance for:

Determination if the purported loan should be regarded as a loan

Treasury functions, including cash pooling, intracompany loans and hedging

Financial guarantees

Captive insurance

Risk-free and risk-adjusted rates of return

These principles are significant in scope and consequences that also allow countries to implement approaches in their domestic legislation, so there will be areas of dispute as this new guidance is implemented and interpreted.

 

http://www.oecd.org/tax/beps/transfer-pricing-guidance-on-financial-transactions-inclusive-framework-on-beps-actions-4-8-10.pdf

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