On 3 July 2018 the OECD published a discussion draft on the transfer pricing of financial transactions, under the Base Erosion and Profit Shifting (BEPS) Action Plan.
The discussion draft provides additional guidance on: the application of the principles contained in the OECD Guidelines to transfer pricing of financial transactions; economically relevant characteristics that should be considered when analysing the terms and conditions of financial transactions; specific transfer pricing issues related to treasury functions, intra-group loans, cash pooling, hedging, guarantees and captive insurance; and questions to commentators. The OECD has invited comments on the paper by 7 September 2018.
The discussion draft can be reviewed here.
Read our summary of the key topics covered, the questions raised and our opinion on the proposed guidance.