Transfer Pricing and Financial Transactions

Current Developments, Relevant Issues and Possible Solutions
1. Auflage 2022
ISBN: 978-3-7073-4452-3
Verlag: Linde Verlag Wien

Buch, Englisch, Band 128, 176 Seiten, KART, Format (B × H): 155 mm x 225 mm, Gewicht: 300 g

Reihe: Schriftenreihe zum Internationalen Steuerrecht

Transfer pricing and financial transactions: Issues and developments

Since years, issues related to transfer pricing and intra-group financing are prominent in the agendas of both taxpayers and governments. The extreme relevance of these topics and the need to address them has attracted the interest of various international organizations for a long time. Already in 1972, the OECD emphasized that these topics required further attention, and the 1979 OECD Transfer Pricing Report dedicated an entire chapter to issues concerning loans. However, the first OECD Transfer Pricing Guidelines issued in 1995 did not include a chapter on these issues. Twenty-five years later, in February 2020, the OECD finally released its 2022 Transfer Pricing Guidelines on Financial Transactions that became Chapter X of the OECD Transfer Pricing Guidelines. Meanwhile, in 2021, the United Nations included these topics in Chapter 9 of its Practical Manual for Developing Countries.

With those welcomed recent developments from the OECD and the UN, the topic is now being extensively discussed, especially considering the necessary implementation of the guidance at the national level and the future answers from the tax courts at national and European levels when dealing with this matter. This publication discusses the most important issues and recent developments related to this topic. Beginning with an in-depth analysis on the accurate delineation of financial transactions, it further deals with the specific transactions concerning loans, financial guarantees, and cash pooling.

This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium held in October 2021 at the WU Vienna University of Economics and Business. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how those issues can be approached in practice.

Autoren/Hrsg.

Lang, Michael

Petruzzi, Raffaele

Fachgebiete

• Rechtswissenschaften Steuerrecht Internationales und Europäisches Steuer-, Bilanz- und Rechnungslegungsrecht
• Wirtschaftswissenschaften Betriebswirtschaft Unternehmensfinanzen Internationales Rechnungswesen
• Rechtswissenschaften Ausländisches Recht Österreich

Über Autor(innen)

Lang, Michael
Michael Lang ist Vorstand des Instituts für Österreichisches und Internationales Steuerrecht, Wissenschaftlicher Leiter des LL.M.-Studiums International Tax Law sowie Sprecher des Doktorandenkollegs „Doctoral Program in International Business Taxation (DIBT)“ der WU.

Petruzzi, Raffaele
Raffaele Petruzzi is the Managing Director of the WU Transfer Pricing Center at the Institute for Austrian and International Tax Law at WU (Vienna University of Economics and Business) and an international tax advisor specializing in international tax and transfer pricing at Baker McKenzie, where is part of the EMEA Transfer Pricing Group and is the Head of the Austria Transfer Pricing Group. Raffaele has gained extensive experience in dealing with topics related to international tax and transfer pricing for many years, both from a professional and an academic side. He is a frequent speaker in international conferences and lecturer of numerous courses all over the world, as well as author of many publications. Finally, amongst others, he is a member of the United Nations Subcommittee on Transfer Pricing, of the International Fiscal Association (IFA), and of Transfer Pricing Economists for Development (TPED). Raffaele holds a Ph.D. in International Business Taxation at WU, an LL.M. in International Tax Law at WU, and an M.Sc. in Business Administration and Law at Bocconi University.