New transfer pricing guidance on financial transactions

On 11 February 2020, the OECD released the final version of the transfer pricing guidance on financial transactions, a long-awaited report after the draft published on 3 July 2018.

The purpose of the report is to clarify the application of OECD Transfer Pricing Guidelines to financial transactions, and to provide guidance with specific issues relating to the pricing of intra-group loans, cash pooling, hedging, financial guarantees and captive insurances.

This Report is particularly relevant for Luxembourg given its role as financial center and the importance of intra-group financial transactions.

For a detailed presentation of the Report, please refer to our Newsflash.