OECD ISSUES DISCUSSION DRAFT WITH EXTENSIVE GUIDANCE ON INTRAGROUP FINANCIAL TRANSACTIONS

Loyens & Loeff on 4th July published an article saying that the OECD had published the long-awaited public discussion draft on financial transactions which provides guidance on general pricing issues in relation to intragroup financing, as well as on specific pricing issues regarding cash pooling, hedging transactions, guarantees and captive insurance structures.  The article says that it provides taxpayers and tax authorities new arguments to defend or challenge both existing and future intragroup financial transactions.  Responses to the draft can be made until 7th September.

https://www.loyensloeff.com/en-us/news-events/news/oecd-issues-discussion-draft-with-extensive-guidance-on-intragroup-financial-transactions

http://www.oecd.org/tax/oecd-releases-beps-discussion-draft-on-the-transfer-pricing-aspects-of-financial-transactions.htm

The Discussion Draft itself is available at –

http://www.oecd.org/tax/transfer-pricing/BEPS-actions-8-10-transfer-pricing-financial-transactions-discussion-draft-2018.pdf

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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