The Organisation for Economic Co-operation and Development (OECD) released its final report with transfer pricing guidance on financial transactions on 11 February 2020. The report discusses the application of the principles included in the 2017 edition of the OECD Transfer Pricing Guidelines (TPG).
This is the first time that guidance on financial transactions is included in the TPG and it should help to reduce transfer pricing disputes and double taxation.
The report highlights that implicit support from being part of a group should be considered in an MNE’s credit rating. This may change the way finance transactions have been priced in Finland, among other changes.