Financial Services Transfer Pricing Perspectives
This Summer edition of Financial Services Transfer Pricing Perspectives focuses on current hot topics within the financial services industry, which is undergoing a constant reform with various regulatory changes throughout the world. In this edition we aim to provide you with an overview of the global transfer pricing developments that will potentially affect your organisation and covers themes such as financial value chain transformation, global measures taken as a response to the OECD Base Erosion and Profit Shifting (BEPS) initiative and impacts on the financial services organisation of regulatory changes.
The articles included in this edition are:
- New Focus on value creation and global value chains highlights how tax and transfer pricing considerations are important parts in the process of a business restructuring and the opportunity for the tax and transfer pricing teams to contribute to the business by supporting their goals and ongoing strategy.
- The parable of the regulator and the tax man in the new alternative investment management world order, highlights commercial changes in the alternative investment management industry.
- Pricing execution challenges ahead for Japanese branches of financial institutions, explores the new guidance on the tax technical aspects of the application of the Authorised OECD Approach into Japanese law.
- Financial services tax transparency propositions, focuses on the unique opportunities arising as a result of country-by-country reporting requirements increasing the amount of information shared.
- Inter-company credit guarantees: to charge or not to charge, provides you with a brief summary of the available guidance on guarantees and shares insights from the Dutch Transfer Pricing practice regarding whether a guarantee constitutes a service rendered to which a fee is due or whether it should be regarded as a “shareholder transaction”.