With the help of TDN’s Technical Partners FTI Consulting, the meeting will examine the technical and management issues that arise following the OCED’s final Transfer Pricing Guidelines on Financial Transactions (TPG-FT) published in February 2020. This meeting builds on a discussion in late 2020 and is a further opportunity to consider how in-house Tax teams should be responding to the new guidelines, especially in the context of recent changes in the debt market.
Attendees can consider the delineation of transactions; the effect of LIBOR transition on existing final structures and consider how the COVID pandemic and availability of comparable data affect the economic analysis to support the arm’s length pricing of debt quantum and interest rate for FY2020 and thereafter. The meeting will also address relevant tax issues arising from financial transactions and treasury functions in the current market condition and what factors businesses should take into account when setting up or changing their funding structure.
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