Transfer pricing perspectives:
Re:solutions moving towards certainty
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| The following articles highlight the challenges and response to intragroup financial transactions as well as outlining the risks presented by the new OECD guidelines for allocating profit to a permanent establishment (PE): Tax controversy and intragroup financial transactions: An emerging battleground In this article, we explain why intragroup financial transactions—related-party loans, credit guarantees, factoring arrangements, cash pools, and other forms of financing and credit risk transfer arrangements—are receiving so much attention from tax authorities. We thoroughly examine the controversy, and discuss ways taxpayers can respond. The transfer pricing challenge of the future: Managing permanent establishment risk The Organisation for Economic Co-operation and Development has released new guidelines for allocating profit to a permanent establishment, adding significant complexity to the tasks of companies’ tax directors. This article lays out in detail the risks to multinationals, and offers practical, step-by-step recommendations for mastering it. |
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