The OECD today called for stakeholders’ input on a discussion draft on financial transactions, which deals with follow-up work in relation to base erosion and profit shifting (BEPS) Actions 8-10, on assuring that transfer pricing outcomes are in line with value creation.
The discussion draft aims to clarify the application of the principles included in the 2017 edition of the OECD Transfer Pricing Guidelines, in particular, the accurate delineation analysis under Chapter I, to financial transactions. The work also addresses specific issues related to the pricing of financial transactions such as treasury function, intra-group loans, cash pooling, hedging, guarantees, and captive insurance.
The discussion draft identifies a number of issues on which feedback is particularly sought.
Comments must be received by September 7.