FSTP Perspectives - Archive

A publication for financial services industry tax and transfer pricing professionals

FSTP Perspectives is a publication focusing solely on transfer pricing and related issues for financial institutions.It offers an insight into trends and developments, tax authorities’ approaches, and “hot” topic issues in financial services transfer pricing. 

Previous Issues

FSTP Perspectives - Spring 2013 edition

Welcome to the spring edition of FSTP 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. 

FSTP Perspectives: Fall 2012 edition
This edition contains articles addressing:

  • Revision of Chapter VI of the OECD Transfer Pricing Guidelines and potential implications to financial services companies
  • Transfer pricing for captive insurance companies
  • Intercompany debt: US court case on the treatment of intercompany loans
  • Attribution of income to US banking branches under the OECD Transfer Pricing Guidelines
  • Latin America update 


October 2010

In this issue:

  • An interview with Barry Schott, Managing Director, Tax Controversy and Dispute Resolution, PwC US
  • Recent transfer pricing developments in China
  • An update on the Indian transfer pricing environment