Thursday, 15 January 2015

BEPS Action 4: Interest Deductions and Other Financial Payments

The BEPS Action Plan calls for Action 4 to develop, among other things, transfer pricing guidance “regarding the pricing of related party financial transactions, including financial and performance guarantees, derivatives (including internal derivatives used in intra-bank dealings), and captive and other insurance arrangements.” However, such transfer pricing guidance is not a topic dealt with in the discussion draft. The discussion draft deals with the other mandate of the Action Plan under Action 4.
Source & more info: Deloitte