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OECD releases BEPS discussion draft on the transfer pricing aspects of financial transactions

OECD releases BEPS discussion draft on transfer pricing

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.

Daniel Head

Partner, National Head of Transfer Pricing in the UK

KPMG in the UK


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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

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