
Our global breadth and country-level depth as a financial transactions transfer pricing (FTTP) network provides us with the tools and experience to deliver tailored, sustainable solutions in a dynamically changing global FTTP environment.
Financial transactions are often the most extensive and material transactions within multinational groups. These transactions are central to getting funding across the multinational group and service liquidity provision, long term funding, and other operational and tax needs. In conjunction with revisions made to the OECD Guidelines, greater scrutiny has been placed on the economic substance of these transactions, the options realistically available to the counterparties, and the ability/capacity to bear risk within entities of a multinational enterprise.There has also been a significant shift in the way in which tax authorities have sought to analyse and challenge intercompany loan, guarantee, cash pooling and other financial transactions from a transfer pricing perspective.
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At the PwC Global TP Conference in London (Oct, 2017), Krishnan Chandrasekhar a PwC U.S. Partner and the Global FT leader, Dan Pybus, a PwC UK Director, and Loic Webb-Martin, a PwC UK, Partner and the UK FT leader discuss the latest trends in TP Financial Transactions.
PwC’s global FTTP network is highly experienced and committed to supporting clients in navigating the complexity of this changing environment, providing support around the entire life-cycle of intercompany treasury activity, including:
We provide assistance in the evaluation of alternative global treasury models, evaluating your specific facts and helping design sustainable transfer pricing policies for intercompany financing transactions. Drawing on our multinational expertise and networks, including in collaboration with our Advisory Treasury teams, we are able to devise practical funding structures, across all liquidity types, through which clients are able to apply technically compliant methodologies in a manner which does not require unnecessary complexity in their implementation.
Financial Transactions Transfer Pricing Leader, Global Tax and Legal Services, PwC Belgium
Daniel Pybus
Financial Transactions Transfer Pricing Leader, EMEA, PwC United Kingdom
Tel: +44 (0)20 7213 1359