The Resource Transfer pricing aspects of intra-group loans in light of the Base Erosion and Profit Shifting Action Plan

Transfer pricing aspects of intra-group loans in light of the Base Erosion and Profit Shifting Action Plan

Label
Transfer pricing aspects of intra-group loans in light of the Base Erosion and Profit Shifting Action Plan
Title
Transfer pricing aspects of intra-group loans in light of the Base Erosion and Profit Shifting Action Plan
Creator
Subject
Language
eng
Summary
This article primarily focuses on transfer pricing aspects of intercompany loans. The analysis takes into consideration the current OECD Transfer Pricing Guidelines as well as the revised transfer pricing guidance issued under the OECD/G20's Base Erosion and Profit Shifting (BEPS) Action Plan. Moreover, the impact of other BEPS-related actions on intercompany loans and their relationship with transfer pricing rules is discussed. Finally, the author concludes by making a suggestion to the OECD to adopt his analysis when providing transfer pricing guidance on intercompany loans
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 44 (2016), no. 12 ; p. 885-902
http://library.link/vocab/creatorName
Chand, V
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD
  • OECD Transfer Pricing Guidelines
  • intercompany loan
  • transfer pricing
  • arm's length principle
  • case law
  • BEPS Project (OECD)
Label
Transfer pricing aspects of intra-group loans in light of the Base Erosion and Profit Shifting Action Plan
Instantiates
Publication
Label
Transfer pricing aspects of intra-group loans in light of the Base Erosion and Profit Shifting Action Plan
Publication

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