Transfer Pricing and Intra-Group Financing is a practical guide that addresses the transfer pricing issues related to intra-group financing transactions. Currently, tax authorities and transfer pricing professionals are focusing on these transactions ??and the application of the arm?? length principle. This growing attention is largely dictated by two factors: (i) the relative importance that financial transactions have in multinational groups and the significant amounts involved; and (ii) the increased awareness of tax authorities (and taxpayers alike) who, having for many years primarily dealt with transfer pricing issues related to goods and services, are now being confronted with the complexity of the pricing of these financial transactions. The so-called ??redit crunch?? which began in late 2007 and in mid-2008 exploded on the financial services industry and the global economy, has also heavily influenced this field of application of the arm?? length principle. The impact of the financial markets on this area of transfer pricing continues today.rn rnThe book starts with an introductory chapter covering the financial markets, treasury functions, economic theory underlying financial transactions and the OECD framework regarding financial instruments. Country chapters detail not only the transfer pricing consequences of financial instruments (e.g. profit participating loans, guarantee fees, cash pooling, factoring, leasing) but also present ideas on how a transfer pricing policy could be constructed for these transactions. The increased likelihood of tax disputes resulting from intercompany financing arrangements reinforces taxpayers??need to revisit existing arrangements and implement policies and procedures that are in line with the new market circumstances and the varying approaches to this issue. Tools to address, substantiate and price intercompany financial transactions are provided throughout the book. Furthermore, practical anecdotes, diagrams and tables are intertwined into the analysis to give the reader some working knowledge of transfer pricing issues related to intra-group financing.rn rnThis book is an invaluable resource for tax practitioners, tax lawyers, tax managers, taxrndirectors of corporations, treasurers and tax authorities, in all facets of transfer pricing andrnintra-group financing.
