Transfer pricing. OECD releases guidance on financial transactions
Spain Tax Alert
The OECD released new transfer pricing guidance on financial transactions on February 11, 2020, giving continuity to Actions 4 and 8 -10 in the 2015 BEPS project, also to the report on this same subject launched for public comment in July 2018 (the document is available here).
This report, arriving after two years of intense debate and work within the OECD, addresses from the standpoint of controlled transactions the treatment of the main types of financial transactions, including loans, guarantees, cash pooling or hedging.
It is of key importance because it (i) updates the contents of the OECD transfer pricing guidelines (by adding a new Chapter X to them) and, (ii) contributes to providing clarity and consistency to both tax authorities and taxpayers on the treatment of these transactions (currently one of the most controversial types), and helps to avoid disputes and double taxation.
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