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 with transfer pricing guidelines.

We set out below the background to the concept of transfer pricing and suitable methodologies for applying intra-group transfer pricing practices that are compliant with OECD guidelines.

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