We are expecting new OECD guidance on the transfer pricing analysis of financing arrangements. Anton Hume and Andrew Stewart (BDO) consider what’s most likely to change.
Since the publication of the ‘final’ BEPS reports in 2015 two of the most difficult areas remained a work in progress with the initial reports concluding only that they should be addressed. One of these the impact of the digital economy has attracted significant attention. The other guidance on the transfer pricing aspects of financing transactions (largely unaddressed by the current OECD transfer pricing guidelines albeit an area where the OECD self-evidently see substantive tax risk) is less ground-breaking but still much needed.
The OECD finally issued a consultation paper on the transfer pricing of financial transactions in July 2018 but it was (unusually) a non-consensus one reflecting many areas of disagreement between the members...
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We are expecting new OECD guidance on the transfer pricing analysis of financing arrangements. Anton Hume and Andrew Stewart (BDO) consider what’s most likely to change.
Since the publication of the ‘final’ BEPS reports in 2015 two of the most difficult areas remained a work in progress with the initial reports concluding only that they should be addressed. One of these the impact of the digital economy has attracted significant attention. The other guidance on the transfer pricing aspects of financing transactions (largely unaddressed by the current OECD transfer pricing guidelines albeit an area where the OECD self-evidently see substantive tax risk) is less ground-breaking but still much needed.
The OECD finally issued a consultation paper on the transfer pricing of financial transactions in July 2018 but it was (unusually) a non-consensus one reflecting many areas of disagreement between the members...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
