Welcome to the fall edition of FSTP Perspectives. 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
We hope you find these articles useful. If you have any questions or comments on these or related transfer pricing issues, please feel free to reach out to your regular PwC transfer pricing contact or a member of the editorial team.