The OECD (2020) Transfer Pricing Guidance on Financial Transactions: Inclusive Framework on BEPS: Actions 4, 8-10
On February 11, 2020, the Organisation for Economic Cooperation and Development (OECD) released a transfer pricing guidance on financial transactions, developed as part of Actions 4, 8-10 of the BEPS (Base Erosion and Profit Sharing) Action Plan. The document is significant because it is the first time the OECD Transfer Pricing Guidelines includes guidance on the transfer pricing aspects of financial transactions, which will contribute to consistency in the interpretation of the arm’s length principle and help avoid transfer pricing disputes and double taxation.
Sections A to E of this report are included in the Guidelines as Chapter X. Section F is added to Section D.1.2.1 in Chapter I of the Guidelines, immediately following paragraph 1.106. The guidance describes the transfer pricing aspects of financial transactions and includes a number of examples to illustrate the principles discussed in this report. Multiple provisions of Cameroon’s Public Finance Law for the 2020 fiscal year, voted in December 2019 were updated to reinforce the legal arsenal to fight transfer pricing and implement the minimum international standards of the BEPS Action Plan and transfer pricing.
The OECD document is accessible here: transfer-pricing-guidance-on-financial-transactions-inclusive-framework-on-beps-actions-4-8-10 oecd or on the OECD website here: https://www.oecd.org/tax/beps/transfer-pricing-guidance-on-financial-transactions-inclusive-framework-on-beps-actions-4-8-10.pdf