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Wednesday, 12 February 2020

OECD releases Transfer Pricing Guidance on Financial Transactions

On February 11, 2020 the OECD released the highly anticipated report “Transfer Pricing Guidance on Financial Transactions” (“the report”), which deals with the follow-up work in relation to Actions 8-10 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project.

 

The 2015 report on BEPS Actions 8-10

The 2015 report on BEPS Actions 8-10 mandated follow-up work on the transfer pricing aspects of financial transactions. Under that mandate, in July 2018 the Discussion Draft on Financial Transactions was published, which aimed to clarify the application of the principles included in the 2017 edition of the OECD Transfer Pricing Guidelines (“Transfer Pricing Guidelines”). The report published by the OECD on the 11th therefore takes account of the comments received in response to the public Discussion Draft.

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