What does the new financial transactions guidance provided by the OECD mean for you?

What is it all about?

More than 18 months after the publication of its non-consensus discussion draft on Financial Transactions (BEPS Actions 8 to 10), the OECD released its ‘final’ report on the transfer pricing of financial transactions on Tuesday 11 February 2020. The original draft left some 25 areas of disagreement, representing a non-consensus position of the OECD’s Committee on Fiscal Affairs. While those areas are largely resolved by the guidance, there remain some issues that have not been definitively addressed.

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Weekly transfer pricing roundup – 20 Feb 2017

I see more and more articles on India’s secondary adjustment and maybe it should be amended before it is enacted. I am part of the camp that doesn’t believe a deemed loan is the most appropriate way to treat a secondary adjustment. The reason for this is that practically it is a nightmare, but maybe I should give India the benefit of the doubt and they may actually be able to pull this off?

As you will see below, more countries are introducing transfer pricing requirements and very soon everyone will have introduced some sort of transfer pricing regulations. I guess that means this blog will continue for a while, which is good news. Happy reading. Continue reading “Weekly transfer pricing roundup – 20 Feb 2017”