On this page there are several transfer pricing agreements that are usefull for financial transactions. Our templates are easy to complete and applicable worldwide. If you have questions please send us a message.
it works as follows
In February 2020, the Organisation for Economic Co-operation and Development (“OECD”) released the report Transfer Pricing Guidance on Financial Transactions: Inclusive Framework on BEPS: Actions 4, 8-10.
In October 2015, as part of the final BEPS package, the OECD/G20 published the reports on Action 4 (Limiting Base Erosion Involving Interest Deductions And Other Financial Payments) and Actions 8-10 (Aligning Transfer Pricing Outcomes with Value Creation). Those reports mandated follow-up work on the transfer pricing aspects of financial transactions.
The report Transfer Pricing Guidance on Financial Transactions is significant because it is the first time the OECD Transfer Pricing Guidelines include guidance on the transfer pricing aspects of financial (services) transactions, which will contribute to consistency in the interpretation of the arm’s length principle and help avoid transfer pricing disputes and double taxation.
The guidance in this report describes the transfer pricing aspects of financial transactions. It also includes a number of examples to illustrate the principles discussed in the report. The report also addresses specific issues related to the pricing of financial transactions (e.g. treasury functions, intra-group loans, cash pooling, hedging, guarantees and captive insurance).
In our product pages you will find some template agreements relating to the above mentioned financial transactions.