Close
Cyprus: Recognising intra-group loans following the OECD’s FTTP guidance
Christos A. Theophilou 31 Mar 2021
Christos Theophilou and Costas Savva of Taxand Cyprus consider how the OECD’s guidance on financial transactions and transfer pricing can be interpreted in consideration of intra-group loans.
Christos Theophilou and Costas Savva of Taxand Cyprus consider how the OECD’s guidance on financial transactions and transfer pricing can be interpreted in consideration of intra-group loans.
On 11 February 2020, the OECD released transfer pricing rules with respect to financial transactions, namely “Transfer Pricing Guidance on Financial Transactions: Inclusive Framework on BEPS: Actions 4, 8-10” (FT Report). The guidance provided in the FT Report is to be included in the OECD transfer pricing guidelines (TPG) as Chapter X.
Notably, the FT Report provides comprehensive guidance to all stakeholders (i.e. taxpayers, tax authorities, tax advisors etc.) on pricing intra-group financial transactions. Furthermore, the FT Report is of great importance as the TPG tend to have a retroactive application, as the TPG are presented as ‘clarifications’.
Continue reading: Cyprus: Recognising intra-group loans following the OECD’s FTTP guidance
For similar content to our Global Guide, subscribe to our mailing list and keep up to date.