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By Nicolas GILLET, Partner, Transfer Pricing Francesca MICHIELIN, Senior Manager, Transfer Pricing, EY Luxembourg
On 11 February 2020, the Organization for Economic Co-operation and Development (OECD) released its final report on transfer pricing guidance for financial transactions (the Report). The Report has been published as follow-up guidance to Base Erosion and Profit Shifting (BEPS) Action 4 and Actions 8-10. It aims to clarify how the principles included in the 2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TPG) should be applied, in particular, the accurate delineation analysis of financial transactions. The Report represents the first time that guidance on financial transactions has been...
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