Intragroup financing & Transfer Pricing

Our global Transfer Pricing experts can provide you with practical analysis of current events linked to intragroup financing and give you the keys to properly manage your transactions.

In February 2020, the OECD published Transfer pricing guidance on financial transactions. It covered specific issues related to the pricing of intragroup financing (e.g. intragroup loans, cash pooling, hedging, guarantees).

Addressing base erosion and profit shifting continues to be a key priority for governments around the globe. As a result, local tax authorities have strengthened their provisions on these transactions.

The analysis of intragroup financing must consider the main characteristics of an agreement (e.g. credit rating of the borrower, maturity, ranking subordination, currency). As the practice has been introduced recently, the analysis carried out to determine the intragroup remuneration may be challenged by local tax authorities, which can lead to judgements from local courts.


Insights into the FTA practical guidelines on intragroup interests - March 2021