OECD discussion draft on transfer pricing | KPMG | UK
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Does the OECD discussion draft on transfer pricing for financial transactions pose more questions than it answers?

OECD discussion draft on transfer pricing

On 3 July 2018 the OECD published a discussion draft on the transfer pricing of financial transactions. The draft provides additional transfer pricing guidance on several types of financial transactions and asks numerous questions of commentators.

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Partner, National Head of Transfer Pricing in the UK

KPMG in the UK

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You can find the discussion draft here.

Key topics discussed in the draft include:

  • 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; and
  • Specific transfer pricing issues related to treasury functions, intra-group loans, cash pooling, hedging, guarantees and captive insurance.

Key themes arising throughout the draft include:

  • The importance of accurate delineation of the actual transaction in advance of considering the pricing;
  • A focus on two sided analyses and consideration of options realistically available; and
  • The concept of implicit group support needing to be taken into account in almost all cases.

Download our report for a more detailed look at the key topics covered by the discussion draft, the questions raised and our opinion on the proposed guidance.

 

For further information please contact: 

Daniel Head

UK Head of Transfer Pricing, KPMG in the UK

E: Daniel.Head@kpmg.co.uk

Aron Elsey

Senior Manager, Transfer Pricing

KPMG in the UK

E: Aron.Elsey@KPMG.co.uk

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