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Managing Directors Michelle Johnson and Stefanie Perrella, Director Andrew Cousins, and Vice Presidents Michael Berbari and Zachary Held in Duff & Phelps' global Transfer Pricing practice, provide U.S. and UK perspectives regarding the OECD’s recent publication Discussion Draft on Financial Transactions addressing the Report on Actions 8-10 of the BEPS Action Plan, which includes transfer pricing guidance for related party financial transactions.
In the October 2018 issue of Bloomberg BNA’s Transfer Pricing Forum, international transfer pricing practitioners identified the current status of the country’s specific rules, best practices and court cases applicable to determining and supporting the arm’s length nature of intercompany financing transactions (including the terms of the instrument and the pricing of the transaction) and the potential impact of the discussion draft.
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The topic on the arm’s length nature of intercompany financing transactions included commentary on the following: