In February 2020, the OECD released the final “Transfer Pricing Guidance on Financial Transactions” in response to additional mandated work as part of the Base Erosion and Profit Shifting (BEPS) Actions 8-10. The document is intended to be an addition to the OECD Transfer Pricing Guidelines and includes guidance for transfer pricing issues on treasury activities including loans, cash pooling, guarantees, and captive insurance companies. Similarly, in April 2019, the Committee of Experts on International Cooperation in Tax Matters released a new draft chapter on financing transactions for the UN Practical Manual on Transfer Pricing for Developing Countries.

In the recent book, Transfer Pricing Developments Around the World 2020, published by Wolters Kluwer (edited by Michael Lang and Raffaele Petruzzi), NERA Associate Director Amanda Pletz and Senior Analyst Diana Kabir contributed a chapter called “Recent Developments on Transfer Pricing and Intra-Group Financing,” in which they provide an analytical framework addressing how to effectively deal with complexities stemming from financing in a transfer pricing context.