Bloomberg Tax
May 3, 2023, 1:01 PM

Intragroup Financial Guarantees Drive MNE Transfer Pricing Plans

Christos  Theophilou
Christos Theophilou
Taxand, Cyprus

Financial transactions are considered to be one of the most significant areas of transfer pricing controversy between taxpayers and tax authorities. On Feb. 11, 2020, the OECD released transfer pricing rules with respect to financial transactions that were then included in chapter X of the 2022 OECD Transfer Pricing Guidelines, and in 2021, the UN included Chapter 9.13 of the 2021 UN Practical Manual to provide guidance for taxpayers and tax authorities on how to analyze and price financial guarantees in transfer pricing.

The potential for abusive transfer pricing practices involving intragroup financial guarantees means tax authorities are vigilant ...

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