Transfer Pricing and Financing | 2023*

Transfer Pricing and Financing | 2023*

In recent years, the interpretation and enforcement of transfer pricing regulations concerning intra-group transactions involving financing functions have become a top priority for both taxpayers and governments. This issue has been a focal point for international organizations since 1972, with the OECD providing extensive guidance through the Transfer Pricing Guidance on Financial Transactions, which was incorporated into Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Following this, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021. This book takes a comprehensive approach to the practical application of transfer pricing rules to specific financing transactions, offering a thorough understanding of how these transactions are taxed between related parties.

Contributions from leading academics and practitioners, building on the work of international organizations, shed light on the complex interactions between transfer pricing and various types of intra-group financial transactions, including:

• loans

• financial guarantees

• cash pooling

• hybrid financing

• factoring

• captive insurance

• asset management

Each chapter offers a well-rounded combination of theoretical insights and practical examples, featuring case studies and references to key case law.

Recognizing that legal clarity in this area remains elusive despite the substantial efforts of the OECD and UN, this book seeks to address this gap by providing principle-based and practical guidance on applying transfer pricing to financial transactions. Tax lawyers, in-house counsel, tax authorities, international organizations, businesses, advisory firms, and academics will find this unparalleled overview and guide invaluable for navigating one of the most critical issues in international taxation.

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