Transfer Pricing for Financial Transactions : Determining Credit Ratings PDF Download
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Author: R.T. Clair
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
With further guidance on related-party financing transactions still to come from the OECD, the authors describe current approaches to determining credit ratings as an anchor for arm's-length pricing of loans, cash pooling and guarantees.
Author: R.T. Clair
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
With further guidance on related-party financing transactions still to come from the OECD, the authors describe current approaches to determining credit ratings as an anchor for arm's-length pricing of loans, cash pooling and guarantees.
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: Raffaele Petruzzi
Publisher: Kluwer Law International B.V.
ISBN: 9403540338
Category : Law
Languages : en
Pages : 261
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Book Description
In recent years, the interpretation and implementation of transfer pricing regulations of intra-group transactions involving financing functions increased exponentially as one of the main priorities of both taxpayers and governments. This topic has also attracted the attention of international organizations since 1972, whereby an extensive guidance has been rendered by the OECD in the Transfer Pricing Guidance on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Not long after, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021. This book’s comprehensive approach to the practical application of transfer pricing rules to specific types of financing transactions ensures an in-depth understanding of the taxation of these transactions between related parties. Chapters contributed by renowned academics and practitioners based also on the work of international organizations elucidate the complex interaction between transfer pricing and the following types of intra-group financial transactions: loans; financial guarantees; cash pooling; hybrid financing; factoring; captive insurance; and asset management. Each contribution contains a balanced mix of theoretical understanding and practical examples, including case studies and references to key case law. Aware that legal certainty in this area remains unachievable despite the relevant work so far of the OECD and the UN, this book aims to alleviate this deficiency with principle-based and practical knowledge on transfer pricing applied to financial transactions. Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics will welcome this matchless overview and guide to one of the most important topics in international taxation.
Author: R. Fossati
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
This article outlines the main concerns and drawbacks that one could confront in attempting to analyse financial transactions by following the principles provided in the Transfer Pricing Guidance on Financial Transactions published by the OECD on 11 February 2020. In essence, it highlights the necessity of assessing the company's creditworthiness and the applicability of the various tools and methodologies available for the identification of the appropriate credit rating of MNE groups and subsidiaries, as well as the validity of the contiguous interrelations between the assets and credit rating of the guarantor with those of the borrower. At the same time, this article specifically aims to provide a practical illustration of the rating methodologies developed by credit rating agencies and thus make it a self-explanatory example for use in the endless discussions regarding the importance of qualitative reasoning for the estimation of the borrower's credit rating.
Author: Anuschka Bakker
Publisher: IBFD
ISBN: 9087221525
Category : Business & Economics
Languages : en
Pages : 593
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Book Description
This book explores transfer pricing issues related to intra-group financing transactions. It is an invaluable resource for tax practitioners, tax lawyers, tax managers, tax directors of corporations, treasurers and tax authorities, in all facets of transfer pricing and intra-group financing.
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: 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: 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: Michael Lang
Publisher: Linde Verlag GmbH
ISBN: 3709411998
Category : Law
Languages : en
Pages : 125
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Book Description
Transfer pricing and financial transactions: Issues and developments Since years, issues related to transfer pricing and intra-group financing are prominent in the agendas of both taxpayers and governments. The extreme relevance of these topics and the need to address them has attracted the interest of various international organizations for a long time. Already in 1972, the OECD emphasized that these topics required further attention, and the 1979 OECD Transfer Pricing Report dedicated an entire chapter to issues concerning loans. However, the first OECD Transfer Pricing Guidelines issued in 1995 did not include a chapter on these issues. Twenty-five years later, in February 2020, the OECD finally released its 2022 Transfer Pricing Guidelines on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines. Meanwhile, in 2021, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries. With those welcomed recent developments from the OECD and the UN, the topic is now being extensively discussed, especially considering the necessary implementation of the guidance at the national level and the future answers from the tax courts at national and European levels when dealing with this matter. This publication discusses the most important issues and recent developments related to this topic. Beginning with an in-depth analysis on the accurate delineation of financial transactions, it further deals with the specific transactions concerning loans, financial guarantees, and cash pooling. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium held in October 2021 at the WU Vienna University of Economics and Business. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how those issues can be approached in practice.
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.
