Mazars Tax Newsletter - OECD transfer pricing guidelines on financial transactions (Part II: Treasury Functions)
The OECD has released in February 2020 the final Transfer Pricing Guidance on Financial Transactions ("Guidance"). The Guidance provides an insight on the arm’s length treatment of various financial transactions among related parties. This is the first time that multinational enterprise (MNE) groups are provided with guidelines on how to structure and price intra-group financial transactions. In our second newsletter, we focus on treasury functions – cash pooling and hedging, guarantees, captive insurance and risk-free and risk adjusted rates of return.
We continue our transfer pricing newsletter where we will discuss the OECD's Transfer Pricing Guidance on Financial Transactions (Guidance) specifically touching on treasury functions – cash pooling and hedging, guarantees, captive insurance and risk-free and risk adjusted rates of return. The discussion about "accurate delineation of the transactions" and "intra-group loans" are covered in our newsletter issued in Part I: Intra-Group Loan.
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