Transfer pricing aspects of Intra - group loans in light of the base erosion and profit shifting action plan

• Autores: Vikram Chand
• Localización: Intertax, ISSN 0165-2826, Vol. 44, Nº. 12, 2016, págs. 885-902
• Idioma: inglés
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• Resumen

  • This article primarily focuses on transfer pricing aspects of intercompany loans. The analysis will take into consideration the current Organisation for Economic Co-operation and Development OECD transfer pricing guidelines as well as the revised transfer pricing guidance issued under the OECD/G20’s Base Erosion and Profit Shifting (BEPS) Action Plan. Moreover, the impact of other BEPS related actions on intercompany loans and their relationship with transfer pricing rules is discussed. Finally, the author concludes by making a suggestion to the OECD to adopt his analysis when providing transfer-pricing guidance on intercompany loans.