4th Cyprus International Tax Conference - Taxand Cyprus segment:
Practical Aspects of the New OECD Transfer Pricing Guidance on Intra-group Financial Transactions.The OECD released new Chapter X of the Transfer Pricing Guidelines (“TPG”) that contains specific guidance on financial transactions and covers treasury functions such as intra-group loans. Notably, the TPG tend not to have an effective date and are usually presented as ‘‘clarifications’’. The consequence is that these clarifications can be considered to apply retroactively to existing transactions, creating significant exposure to transfer pricing disputes and double taxation.
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