This first part of a two-part article discusses the importance of the final transfer pricing guidance on financial transactions, the role of accurate delineation as regards financial transactions, the application of the arm’s-length principle to determine if a financial instrument qualifies as debt or equity, and treasury functions and the relevant considerations required when applying the arm’s-length principle to intra-group loans.
Tax Management Transfer Pricing Report
Tax Law

Jie-A-Joen, C.S.J., van Herksen, M.I.E., & Bai, F. (2020). INSIGHT: New OECD Guidance on Transfer Pricing Aspects of Financial Transactions—Part 1. Tax Management Transfer Pricing Report. Retrieved from