The transfer pricing aspects of cross-border financing arrangements continues to be a hot topic for multinationals and tax authorities worldwide. In February this year, the OECD released its long-awaited final paper on the transfer pricing aspects of financial transactions, which will become Chapter X of the OECD Guidelines.
This session covered the key aspects of the finalised chapter and the implications for multinational groups in their approach to the application of the arm's length principle to financial transactions.