Transfer Pricing and Financing

作者： Raffaele Petruzzi; Michael Lang
出版商： Kluwer Law International
ISBN: 9789403540221
出版时间 March 2023
规格： Hardback
适应领域： International ? 免责申明：
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In recent years, the interpretation and implementation of transfer pricing regulations of intra-group transactions involving financing functions increased exponentially as one of the main priorities of both taxpayers and governments. This topic has also attracted the attention of international organizations since 1972, whereby an extensive guidance has been rendered by the OECD in the Transfer Pricing Guidance on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Not long after, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021. This book’s comprehensive approach to the practical application of transfer pricing rules to specific types of financing transactions ensures an in-depth understanding of the taxation of these transactions between related parties.

Chapters contributed by renowned academics and practitioners based also on the work of international organizations elucidate the complex interaction between transfer pricing and the following types of intra-group financial transactions:
- loans;
- financial guarantees;
- cash pooling;
- hybrid financing;
- factoring;
- captive insurance; and
- asset management.
Each contribution contains a balanced mix of theoretical understanding and practical examples, including case studies and references to key case law.

Aware that legal certainty in this area remains unachievable despite the relevant work so far of the OECD and the UN, this book aims to alleviate this deficiency with principle-based and practical knowledge on transfer pricing applied to financial transactions. Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics will welcome this matchless overview and guide to one of the most important topics in international taxation.
Editors

Contributors

Preface

CHAPTER 1

Introduction

CHAPTER 2

Transfer pricing aspects of loans

Antonio Russo, Andre Dekker & Tim Böhne

CHAPTER 3

Transfer Pricing Aspects of Financial Guarantees

Andrew Hickman and Marcelo H. B. Moura

CHAPTER 4

Cash Pooling

CHAPTER 5

Hybrid Financing

CHAPTER 6

Transfer Pricing Aspects of Factoring

CHAPTER 7

Transfer Pricing Principles for Captive Insurance

Stanley J Hales & and Lucie Hovorkova

CHAPTER 8

Transfer Pricing Aspects of Asset Management

Dr. Georg Dettmann

Table of Cases

Index

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