Transfer Pricing for Intra-Group Financial Transactions: Salient features, prominent court cases and the Dutch transfer pricing perspective

This ebook provides an in-depth analysis of the OECD’s Chapter X guidance on transfer pricing for intra-group financial transactions, such as loans, financial guarantees, and cash pooling. It offers insights into global case law and best practices for multinational enterprises (MNEs) to ensure compliance with the arm’s length principle. The booklet highlights key recommendations for businesses to manage and document their intra-group financing in accordance with international standards.

The “Transfer Pricing for Intra-Group Financial Transactions” booklet by NovioTax offers comprehensive insights into the OECD’s 2020 guidelines on the arm’s length treatment of intercompany financial arrangements. It provides detailed coverage of intra-group loans, financial guarantees, treasury functions, and cash pooling arrangements, highlighting the economic rationality required in these transactions. The booklet also explores key court cases, such as Chevron and General Electric, and how they have shaped global transfer pricing practices.

In addition, the Dutch transfer pricing perspective is examined, offering practical advice for multinational enterprises (MNEs) on how to align their financing practices with international guidelines. The booklet emphasizes the importance of documenting and pricing intra-group financial transactions correctly to prevent disputes with tax authorities. Suitable for both practitioners and companies, it provides critical guidance for mitigating risks and complying with global transfer pricing standards.

 

 

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Patrick T.F. Schrievers

Patrick T.F. Schrievers is a tax lawyer and member of the

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