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How to price intragroup financial transactions?

A new chapter on intra-group financial transactions has been introduced into the OECD Transfer Pricing Guidelines. These guidelines are long overdue for transfer pricing practitioners but the impact of these guidelines should be felt by tax and non-tax professionals alike in a range of day-to-day and one-off financial transactions between group entities including the provision of loans and funding facilities, provision of guarantees, treasury operations and hedging activities performed by one group entity for other group entities, cash pooling arrangements, transfers of receivables or loan balances and so on. How do you ensure that these financial transactions between group entities are carried out under terms that are consistent with the arm's length principle? Are there practical approaches that can be useful as a guide for non-tax treasury colleagues? What are some of the common pitfalls that should be avoided?

Tuesday

26

March 2024

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