Intra-Group Treasury Operations Seen Through Tax Glasses

On 11 February 2020, the Organisation for Economic Co-operation and Development (OECD) published, as part of its Base Erosion and Profit Shifting (BEPS) project, the final guidance on transfer pricing aspects of intercompany financial transactions (the Report). For the first time ever, the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (the OECD […]