On July 3, 2018, the OECD published a 43-page discussion draft on cross-border financial transactions. The OECD Transfer Pricing Guidelines (TPG) as well as most national regulations currently only contain rudimentary guidance on the subject of intra-group financing, meaning the discussion draft has been awaited with great interest. The publication of the discussion draft was announced about two years ago, but was postponed several times due to inconsistencies among the OECD member states. For this reason, it is not surprising that the discussion draft does not present a consensus of the OECD, but rather an overview of concepts regarding financial transactions.
78 interested parties, including T/A Economics and WTS Germany, as part of WTS Global, submitted comments to the OECD Discussion Draft1 . The following provides an overview of the most fundamental issues raised by T/A Economics and WTS Germany:
Accordingly, we have suggested that the next versions of the discussion draft should touch upon these points.
Our complete set of comments can be accessed at the following link.
1 The discussion draft can be accessed at the following link: http://www.oecd.org/tax/transfer-pricing/oecd-releases-beps-discussion-draft-on-the-transfer-pricing-aspects-of-financial-transactions.htm
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