Japan Tax Bulletin

OECD Transfer Pricing Guidance on Financial Transactions

On 11 February 2020, as part of tax base erosion and profit shifting project, the OECD released final Transfer Pricing Guidance on financial transactions. The Guidance mainly addressed regarding the intra-group loans, cash pooling arrangements, financial guarantees, and captive insurance.
This article aims to summarize the key chapters of the Guidance and the possible impact the Guidance may have on transfer pricing arrangements for financial transactions within a multinational enterprise group.

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