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14 January 2019

Intercompany financing transactions: a growing source of transfer pricing risk

Tax administrators are increasingly focused on the transfer pricing treatment of intercompany financing transactions (ICFT). This increased scrutiny is driving a new phase of tax disputes, with little consistency in ICFT treatment between jurisdictions – although the Organisation for Economic Co-operation and Development (OECD) continues its work to address the issue. In the meantime, taxpayers are struggling to understand what is acceptable in this changing environment.

A recent report, the second in EY “Eight for 2018 and beyond” transfer pricing series, discusses common ICFT technical issues, challenges and important considerations for taxpayers.

Additional information and links to past newsletters can be found in the attached Newsletter PDF.

Document ID: 2019-5038

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