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OECD Issues Consultation Document On The Transfer Pricing Aspects Of Financial Transactions

Wednesday 11th July 2018

The OECD has recently issued a discussion draft on financial transactions, which deals with follow up work in relation to the BEPS Action Plan, specifically Actions 8-10, to ensure 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, which does not yet represent a consensus position of the Committee on Fiscal Affairs or its subsidiary bodies, aims 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.

The work also addresses specific issues related to the pricing of financial transactions such as treasury function, intra-group loans, cash pooling, hedging, guarantees and captive insurance.

Comments have been invited on the discussion draft by 7 September 2018.


If you would like further details on the discussion draft, please contact Keith Rushen on 0207 486 2378.

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