Financial transactions (loans)

Resource Information

The work Financial transactions (loans) represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Financial transactions (loans)

Subject

• BEPS Project (OECD)
• PE
• financing
• hybrid mismatch
• intra-group financing
• loan
• transfer pricing

Language

eng

Summary

While the OECD turns its attention to the treatment of financial transactions in its Transfer Pricing Guidelines, most countries already have had to deal with intra-group financial transactions, and many countries have been independently developing views about analytical rules and principles to deal with the increased importance many see this subject having in regard to their tax bases. This issue deals with the ways in which countries currently address the issue of related party loans or related party guarantee situations. Even in the absence of OECD guidelines, tax examiners see these transactions, and in some way must deal with them. This issue looks at the "baseline" of countries' positions, before the OECD has spoken

Citation source

In: Transfer pricing forum. - Arlington. - Vol. 9 (2018), no. 1 (March) ; 123 p

Geographic coverage

International

Language note

English