A discussion draft on financial transactions dealing with follow-up work to Actions 8–10 (“Assure that transfer pricing outcomes are in line with value creation”) of the BEPS Action Plan was published by the OECD recently.

The 2015 report on BEPS Actions 8–10 mandated follow-up work on the transfer pricing aspects of financial transactions. The discussion draft aims to clarify the application of the principles included in the 2017 edition of the OECD Transfer Pricing Guidelines. The draft also addresses specific issues related to the pricing of financial transactions such as treasury function, intra-group loans, cash pooling, hedging, guarantees and captive insurance.

Interested parties are invited to send their comments on this discussion draft, and to respond to the specific questions included in the boxes, by 7 September 2018 by e-mail to TransferPricing@oecd.org