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The transfer pricing of financing transactions: OECD guidance

Since the publication of the ‘final’ BEPS reports in 2015 two of the most difficult areas remained a work in progress with the initial reports concluding only that they should be addressed. One of these the impact of the digital economy has attracted significant attention. The other guidance on the transfer pricing aspects of financing transactions (largely unaddressed by the current OECD transfer pricing guidelines albeit an area where the OECD self-evidently see substantive tax risk) is less ground-breaking but still much needed.

The OECD finally issued a consultation paper on the transfer pricing of financial transactions in July 2018 but it was (unusually) a non-consensus one reflecting many areas of disagreement between the members of the OECD’s Committee on Fiscal Affairs. It has taken more than a year but the OECD has now substantively finalised its work and has a...

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