OECD's discussion draft on financial transactions' TP aspects focuses on delineation analysis

Jul 03,2018

OECD releases discussion draft on transfer pricing aspects of financial transactions as a part of its follow up work in relation to Actions 8-10 of the BEPS Project;  Discussion draft provides guidance on application of principles contained in the OECD TP Guidelines to financial transactions, particularly on how accurate delineation analysis (under Chapter I) applies to capital structure of an MNE within an MNE Group; Discussion draft...

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