Financial Services Transfer Pricing Perspectives
This edition contains articles addressing:
- Findings from the PwC FSTP global network survey covering 40 countries. The survey gathered key information on the current legislative transfer pricing environment on inter-company loans and offers general guidance to the reader on a range of inter-company financial transactions, related transfer pricing issues and provides an aid for transfer pricing policy implementation.
- An overview of initiatives by the OECD to introduce and provide guidance on what can be referred to as the “substance-over-form” concept in international taxation. The article provides some considerations on how these key characteristics can be addressed in the context of transfer pricing by providing some economic concepts.
- A discussion of the Dodd-Frank Wall Street Reform and Consumer Protection Act (DFA) and the challenges facing financial institutions in designing and implementing globally consistent transfer pricing policies and complying with the operational and strategic implications of the DFA implementation.
- A discussion on the new Law 12715 issued by the Brazilian government introducing changes to the existing Brazilian transfer pricing regulations, specifically on deductibility and pricing of interest on related party loans.