Transfer Pricing Aspects of Cash Pooling : a Closer Look at the OECD Discussion Draft on Financial Transactions PDF Download
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Author: G. De Robertis
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
The transfer pricing of cash pooling arrangements has, as case law evidences, attracted considerably more attention in recent years from tax authorities and is getting more and more complex. More jurisdictions are expected to introduce specific guidance, following the impending release of the OECD Discussion Draft on Transfer Pricing of Financial Transactions. As a result, a higher level of scrutiny of such arrangements is anticipated. This article provides an overview of the evolving transfer pricing aspects of cash pooling, highlighting the main relevant and complex issues that need to be addressed.
Author: G. De Robertis
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
The transfer pricing of cash pooling arrangements has, as case law evidences, attracted considerably more attention in recent years from tax authorities and is getting more and more complex. More jurisdictions are expected to introduce specific guidance, following the impending release of the OECD Discussion Draft on Transfer Pricing of Financial Transactions. As a result, a higher level of scrutiny of such arrangements is anticipated. This article provides an overview of the evolving transfer pricing aspects of cash pooling, highlighting the main relevant and complex issues that need to be addressed.
Author: Malik Hill
Publisher:
ISBN:
Category :
Languages : en
Pages : 134
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Book Description
In this monograph M. Hill will focus on how treasury transformation can support your transfer pricing compliance and streamline your inter-company finance processes, more specifically the pricing of indo-company loans financial guarantees and the determination of internal cashflow and in our bank interest rates First the author shall start by giving you some more background on transfer pricing and why it is important for corporate treasurers secondly the author will focus on the arm's length pricing of inter-company loans and financial guarantees stand alone financial transactions within the group, thirdly the author will switch towards four types of transaction, the determination of internal in-house bank interest rates and cash flow rates as there is much more complexity in this process compared to into company loans and then lastly the author will give you the key takeaways and also suggests designers approach based on client cases.
Author: O. Moerer
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
This article examines the OECD's Discussion Draft on financial transactions and conclude whilst the Draft is a small step in terms of guidance, it is a giant leap for financial transactions transfer pricing.
Author: M. van Herksen
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
This article discusses the discussion draft on the transfer pricing (TP) aspects of financial transactions released by the OECD for public comments on 3 July 2018.
Author: R. Petruzzi
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
Even though the OECD BEPS project has addressed numerous issues in the Final Reports published in October 2015, the transfer pricing aspects of financial transactions within multinational enterprises, to a main extent, have not been specifically covered by the scope of these reports. What is more, this topic was also only partially dealt with in the pre-BEPS OECD Transfer Pricing Guidelines. However, the lack of extensive guidance on financial transactions is intended to be addressed by the current work of the OECD. The OECD published a Discussion Draft in July 2018 (DD 2018) in order to lead a public discourse on this topic. When it comes to financial transactions, one of the key issues is the creditworthiness of the transaction itself, commonly expressed by a so-called "credit rating". This topic was also addressed in the DD 2018, where the OECD invited commentators to deal with the questions of whether (i) the group rating or (ii) the stand-alone rating should be considered as relevant when it comes to a transfer pricing analysis of financial transactions.
Author: Yariv Brauner
Publisher: Edward Elgar Publishing
ISBN: 1788975375
Category : Law
Languages : en
Pages : 416
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Book Description
Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264265120
Category :
Languages : en
Pages : 612
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Book Description
This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.
Author: Robert Danon
Publisher: Kluwer Law International B.V.
ISBN: 9403540354
Category : Law
Languages : en
Pages : 1053
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Book Description
It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial transactions. With in-depth analysis of the legislation and market developments that fuel the diverse range of financing options available to market participants – and loaded with practical examples and case studies that cover the legal and economic considerations that arise when analysing intra-group finance – the contributors examine such topics and issues as the following: national anti-abuse rules applicable to financial transactions; tax treaty issues; role of credit ratings and impact of implicit support; loans, cash pooling, financial guarantees; transfer pricing aspects of performance guarantees; ‘mezzanine’ financing; considerations for crypto financing; impact of crises situations such as COVID-19; how treasury operations can be structured in a group and the decision-making process involved; how hedges offset or mitigate risks; how to apply the arm’s length principle to factoring and captive insurance transactions; comparability analysis for various transactions; special considerations for transactions carried out by a permanent establishment; EU state aid and its interaction with transfer pricing rules; dispute prevention and resolution tools under the OECD, UN, and EU frameworks; and developing countries’ perspectives, focusing on Brazil, India, and South Africa. Given the challenges facing taxpayers and tax authorities alike, this book will prove an immeasurably valuable reference guide to support tax practitioners, tax administrations, and tax scholars in developing standards and policies in dealing with intra-group financing issues.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264192743
Category :
Languages : en
Pages : 91
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Book Description
This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.
Author: United Nations
Publisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 672
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Book Description
The Manual is a response to the need, often expressed by developing countries, for clearer guidance on the policy and administrative aspects of applying transfer pricing (profit shifting) analysis to some of the transactions of multinational enterprises (MNEs) in particular.
