OECD releases BEPS discussion draft on transfer pricing | KPMG | UK
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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.

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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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