Transfer Pricing and Financing

Raffaele Petruzzi (Editor), Michael Lang (Editor)

ISBN: 9789403540221

Published: March 2023

Format: Hardback

Language: English

Publisher: Kluwer Law International

Description

In recent years, the interpretation and implementation of transfer pricing regulations of intra-group transactions involving financing functions has increased exponentially as one of the main priorities of both taxpayers and governments. This topic has also attracted the attention of international organizations since 1972, with extensive guidance rendered by the OECD in the Transfer Pricing Guidance on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines in February 2020. Not long after, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries in 2021.

This book's comprehensive approach to the practical application of transfer pricing rules to specific types of financing transactions ensures an in-depth understanding of the taxation of these transactions between related parties. Chapters contributed by renowned academics and practitioners, based also on the work of international organizations, elucidate the complex interaction between transfer pricing and loans, financial guarantees, cash pooling, hybrid financing, factoring, captive insurance, and asset management. Each contribution contains a balanced mix of theoretical understanding and practical examples, including case studies and references to key case law.

Key Features

• Article-by-article style analysis of transfer pricing rules applied to intra-group financing transactions
• Grounded in the OECD's Transfer Pricing Guidance on Financial Transactions (Chapter X, February 2020)
• Incorporates the UN's Practical Manual for Developing Countries (Chapter 9, 2021)
• Chapter-by-chapter treatment of loans, financial guarantees, cash pooling, hybrid financing, factoring, captive insurance, and asset management
• Case studies and references to key case law throughout
• Contributions from renowned academics and practitioners in international tax

Coverage

Transfer pricing aspects of loans; financial guarantees; cash pooling; hybrid financing; factoring; captive insurance; and asset management. Each chapter combines principle-based analysis with practical, real-world application.

About the Authors

Raffaele Petruzzi and Michael Lang lead a team of academics and practitioners who bring together theoretical grounding and hands-on transfer pricing experience. Contributing authors include Antonio Russo, Andre Dekker, Tim Böhne, Andrew Hickman, Marcelo H. B. Moura, Stanley J. Hales, Lucie Hovorkova, and Dr. Georg Dettmann, among others.

Table of Contents

Preface
Chapter 1. Introduction
Chapter 2. Transfer Pricing Aspects of Loans
Antonio Russo, Andre Dekker & Tim Böhne
Chapter 3. Transfer Pricing Aspects of Financial Guarantees
Andrew Hickman and Marcelo H. B. Moura
Chapter 4. Cash Pooling
Chapter 5. Hybrid Financing
Chapter 6. Transfer Pricing Aspects of Factoring
Chapter 7. Transfer Pricing Principles for Captive Insurance
Stanley J. Hales & Lucie Hovorkova
Chapter 8. Transfer Pricing Aspects of Asset Management
Dr. Georg Dettmann
Table of Cases
Index

Why buy this book?

• Understand how transfer pricing rules apply in practice to each major type of intra-group financing transaction
• Base your advice on OECD and UN guidance alongside real case studies and case law
• A matchless overview for tax lawyers, in-house tax counsel, tax authorities, international organizations, and advisory firms

Keywords

Transfer Pricing, Financing, Loans, Financial Guarantees, Cash Pooling, Hybrid Financing, Factoring, Captive Insurance, Asset Management, International Tax Law

Target Audience

Tax Lawyers, In-House Tax Counsel, Tax Authorities, International Organizations, Business Communities, Advisory Firms, Academics

Genre

Legal Commentary, Taxation, International Tax Law, Academic Reference, Professional Reference

FAQs

1. Q: What does "Transfer Pricing and Financing" cover?
   A: It is a comprehensive commentary on how transfer pricing rules apply to intra-group financing transactions, including loans, guarantees, cash pooling, hybrid financing, factoring, captive insurance, and asset management.

2. Q: Which guidance does the book rely on?
   A: It is grounded in the OECD's Transfer Pricing Guidance on Financial Transactions (Chapter X, 2020) and the UN's Practical Manual for Developing Countries (Chapter 9, 2021).

3. Q: Who are the editors?
   A: The book is edited by Raffaele Petruzzi and Michael Lang, with chapters contributed by leading international tax academics and practitioners.

4. Q: Who should read this book?
   A: Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics working in international taxation.

5. Q: How can I purchase this book?
   A: It's available on clnzbooks.com with secure, reliable checkout options.

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