The Tax Executives Institute has responded to the OECD’s public discussion draft on the transfer pricing aspects of financial transactions.
The discussion draft 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 Institute’s submission focused on the need for clear guidance from the OECD on the many issues discussed in the draft.
These issues include the potential recharacterization of a financial instrument, the proper interest rate on a debt instrument, the treatment of guarantees and their related fees, as well as the proper approach to captive insurance arrangements.
Read the full submission here.