On February 11, 2020, the OECD issued its final Transfer Pricing Guidance on Financial Transactions in a 46 page document which the OECD widely disseminated and which can be found on the OECD website. The report builds on the discussion contained in the non-consensus Discussion Draft on Financial Transactions published in July 2018 (“2018 Discussion Draft”). As the guidance is final, it will likely be heavily relied upon by many tax authorities when scrutinizing financial transactions.
The guidance contains five sections:
1. Interaction With Guidance In Section D.1 of Chapter 1
2. Treasury function
3. Financial Guarantees
4. Captive Insurance
5. Risk-Free And Risk-Adjusted Rates of Return