On 11 February 2020, the Organization for Economic Co-operation and Development (OECD) released its final report with transfer pricing guidance on financial transactions (the Report). It aims to clarify the application of the principles included in the 2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TPG). The Report represents the first time that guidance on financial transactions is included in the OECD TPG, with the objective of creating consistency in the application of transfer pricing and helping to reduce transfer pricing disputes and double taxation. 

In response to the guidance and to discuss key messages and implications arising therefrom, EY will be hosting the following global webcast:

Date:  Monday, 23 March 2020

Time:  10:30-12:00 New York; 22:30-24:00 Singapore; 14:30-16:00 London; 15:30-17:00 CET

Registration: To register for this event, go to https://www.ey.com/en_gl/webcasts/2020/03/oecd-guidance-on-financial-transactions-transfer-pricing

In this webcast, hear from EY multinational financial transactions transfer pricing professionals, about the key messages, implications and potential actions for business in responding to the guidance. Join an EY panel moderated by Ronald van den Brekel, EMEIA Transfer Pricing Leader, for an interactive discussion including consideration of:

      The accurate delineation of the balance of debt and equity, guaranteed loans and the terms of funding;

      Functional substance requirements for intra-group lenders;

      The implications of the guidance for cash pooling arrangements;

      The impact of implicit support on determining creditworthiness;

      International perspectives on the guidance; and

      Next steps that groups may wish to consider in response to the guidance.

As the guidance is likely to have implications for the transfer pricing of many group financial transactions please register your interest in attendance today.

Should you have any questions, please address them to EY Ukraine Tax & Law specialists: https://www.ey.com/en_ua/tax ‚Äč