Transfer Pricing and Financing

Chapters contributed by renowned academics and practitioners based also on the work of international organizations elucidate the complex interaction between transfer pricing and the following types of intra-group financial transactions:

• 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.

Aware that legal certainty in this area remains unachievable despite the relevant work so far of the OECD and the UN, this book aims to alleviate this deficiency with principle-based and practical knowledge on transfer pricing applied to financial transactions. Tax lawyers, in-house tax counsel, tax authorities, international organizations, business communities, advisory firms, and academics will welcome this matchless overview and guide to one of the most important topics in international taxation.