Transfer pricing is consistently rated as one of the major tax issues by tax directors and CFOs of
large multinational organisations. While transfer pricing rules are common across all industries,
unique characteristics present in the financial services industry: the rules can raise complex issues in their application.
This paper:
- identifies the hot current and future issues affecting financial service organisations
- shares practical experiences of the recent OECD guidelines covering attribution of profits to PEs, global trading and insurance
- advises of the high ATO risk areas for the Industry.