BEPS Consultation

BEPS Action 4: Interest Deductions and Other Financial Payments

On 18 December 2014, the OECD, as part of its work on the Action Plan to address Base Erosion and Profit Shifting (BEPS), released a Public Discussion Draft on Action 4 in relation to the deductibility of interest expense and economically equivalent financing payments. The Discussion Draft outlines three main alternatives to address non-taxation through the use of interest deductions:

  • Deduction limitations based on group attributes
  • Deduction limitations based on fixed economic ratios and
  • Targeted ...
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Transfer Pricing Methodology for Intra- Group Lending &Treasury Transactions

The increased focus on Base Erosion and Profit Shifting (BEPS) in the multi-national environment will have many corporate treasurers re-considering their pricing methodology on intra-group lending and treasury transactions. Pricing on intra group lending, FX, credit support, guarantees and options are all likely to once again come under the spotlight during 2015. Ensuring a robust, well documented and transparent transfer pricing methodology is in place will reduce your risk exposure on these transactions and ensure that you are fully compliant ...

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