Switzerland: OECD’s guidance on financial transactions
Stephan Pfenninger 07 May 2020
Evaluating the transfer pricing impact on shareholder loans tofund real estate ventures in Switzerland
Evaluating the transfer pricing impact on shareholder loans to fund real estate ventures in Switzerland.
Stephan Pfenninger and Hendrik Blankenstein in the following discuss the recently published OECD Transfer Pricing Guidance on Financial Transactions (OECD) and evaluate the transfer pricing impact on shareholder loans to fund real estate ventures in Switzerland. The OECD report covers the transfer pricing aspects of various intercompany finance transactions, such as loans, financial guarantees, cash-pooling,hedging and captive insurance companies. The OECD now provides detailed guidance supporting taxpayers as well as tax authorities in analysing shareholder loans and in determining arms’ length interest rates.
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