Jun

    Virtual 20th U.S. and Europe Tax Practice Trends: OECD Financial Transactions Report

    11 AM EDT

    This discussion draft provides guidance on the application of the principles underlying the OECD-Transfer Pricing Guidelines to financial transactions, elaborates on the delineation analysis in relation to the capital structure of an MNE within an MNE group.

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    Under the mandate of the OECD-reports on Actions 4 and 8-10 of the BEPS Action Plan, the OECD issued a non-consensus discussion draft on financial transactions in September 2018. This discussion draft provides guidance on the application of the principles underlying the OECD-Transfer Pricing Guidelines to financial transactions, elaborates on the delineation analysis in relation to the capital structure of an MNE within an MNE group. It furthermore clarifies the possibility of countries to implement approaches to address capital structure and interest deductibility under their domestic legislation, outlines the economically relevant characteristics that inform the analysis of terms and conditions of financial transactions and addresses specific issues related to the pricing of financial transactions such as treasury function, intra-group loans, cash pooling, hedging, guarantees and captive insurance.

    This panel will focus on the impact of the discussion draft (or the final report when issued) on the current practice in respect of the arm’s length pricing of treasury activities including cash pooling, intercompany loans and guarantees.

    Panelists:

    • Peter Flipsen, Simmons & Simmons LLP, Amsterdam
    • E. Miller Williams, EY, Washington, DC
    • Jessica Kemp, Travers Smith LLP, London
    • Matthias Scheifele, Hengeler Mueller, Munich
    • Heikki Wahlroos, Borenius, Helsinki
    • Christian Wimpissinger, Binder Grösswang, Vienna

    Event Details

    Duration

    95

    Format

    Web

    Date

    Jun 23, 2020

    2020-06-23T11:00:00-04:00 2020-06-23T12:35:00-04:00 Virtual 20th U.S. and Europe Tax Practice Trends: OECD Financial Transactions Report

    This discussion draft provides guidance on the application of the principles underlying the OECD-Transfer Pricing Guidelines to financial transactions, elaborates on the delineation analysis in relation to the capital structure of an MNE within an MNE group.

    Sponsors

    Section of Taxation

    MCLE Information

    The ABA will seek 1.50 CLE credit hours in 60-minute-hour states, and 1.80 CLE credit hours in 50-minute states. Credit hours are estimated and are subject to each state’s approval and credit rounding rules.

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