The OECD released the Transfer Pricing Guidelines on Financial Transactions (TPG-FT) in February 2020. The detailed guidance applies the Arm’s Length Principle to intragroup financial transactions such as capital structure (debt:equity mix), intercompany loans, cash pooling and captive insurance.
Does the guidance add clarity? It will be important that companies consider whether and how the TPG-FT may apply within their group and review their processes and documentation to ensure adherence with the new guidelines. How should large businesses adapt? Will it lead to more enquiries from tax authorities? This session will highlight key areas of the guidelines but the main focus will be to have an open practical discussion as to what actions other corporates are taking in response to the new guidelines.
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