White Paper

Mastering Financial Transaction Transfer Pricing

Financial Transaction Transfer Pricing has been subject to intense scrutiny in recent years. The publication of Chapter X by the OECD in 2020, which provided additional guidance on approaching these transactions, along with various macroeconomic events such as the COVID-19 pandemic and subsequent global policies to combat inflation, has drawn increased attention from tax authorities.

In response, multinational enterprises (MNEs) are compelled to proactively develop robust Transfer Pricing documentation to mitigate the risks associated with potential challenges from tax authorities. The Transfer Pricing implications of intra-group loans must be thoroughly assessed, as penalties for non-compliance are often severe (e.g., withholding taxes, penalties, potential double taxation, deniability of interest deduction, time consuming disputes, etc.).

This paper offers an overview of the current tax authority environment concerning financial transactions, and presents several recommendations for improving the Transfer Pricing position of MNEs for these transactions. Finally, it outlines how the Zanders Transfer Pricing Suite assists its client in addressing these challenges.

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