Share with your friends

KPMG report: OECD discussion draft, transfer pricing of financial transactions

OECD discussion draft, transfer pricing

The Organisation for Economic Cooperation and Development (OECD) in early July 2018 released a discussion draft on the transfer pricing aspects of financial transactions.


Related content

KPMG’s Global Transfer Pricing Services practice provided comments in response to the discussion draft. Read the KPMG comments [PDF 250 KB] and an executive summary [PDF 46 KB] of these comments.


The OECD’s discussion draft on financial transactions [PDF 1.1 MB] concerns a follow-up to base erosion and profit shifting (BEPS) Actions 8-10 (Assure that transfer pricing outcomes are in line with value creation). 

The 2015 report on BEPS Actions 8-10 mandated follow-up work on the transfer pricing aspects of financial transactions. Under that mandate, the discussion draft released is intended 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. Also addressed are specific issues related to the pricing of financial transactions such as treasury function, intra-group loans, cash pooling, hedging, guarantees, and captive insurance.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal