In this second part, they discuss the new transfer pricing guidance on financial transactions as it applies to cash pooling, hedging, financial guarantees, and captive insurance, which are all part of new Chapter X, and the new guidance on risk free rates of return and risk-adjusted rates of return that will be included in section D.1.2.1 called Analysis of risks in commercial or financial relations in Chapter I. Please refer to Part 1 of the authors’ article, which discusses the guidance of Chapter X in relation to the accurate delineation of financial transactions, the application of the arm’s-length principle to determine if a financial instrument qualifies as debt or equity, 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