09 July 2018 OECD releases first discussion draft on transfer pricing aspects of financial transactions The Organisation for Economic Co-operation and Development (OECD) released the first public discussion draft on the transfer pricing aspects of financial transactions (the Discussion Draft) on July 3. The Discussion Draft, which has been published as follow up work in relation to Base Erosion and Profit Shifting (BEPS) Actions 8-10, aims to clarify the application of the principles included in the 2017 edition of OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TPG), covering the accurate delineation of financial transactions, and addressing specific issues related to the pricing of financial transactions, such as treasury function, intra-group loans, credit ratings, cash pooling, hedging, guarantees, and captive insurance. Document ID: 2018-1349 |
