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May 22, 2020

Thursday, 28 May 2020 | BorderCrossings... With EY transfer pricing and tax professionals (1 pm ET)

The forthcoming Chapter X of the OECD Transfer Pricing Guidelines: Financial Transactions

The Organisation for Economic Co-operation and Development (OECD) plans to incorporate its final Transfer Pricing Guidelines on Financial Transactions (the Report), released earlier this year, into a new Chapter X of the OECD Transfer Pricing Guidelines. The OECD has not stated specifically how or when the Report will be integrated. While the Report does not directly change US domestic law, it is unclear how it will affect the existing interpretation of US IRC Sections 385 and 482. Any divergence between US domestic law and the Report may lead to increased controversy and may result in a greater need for competent authority proceedings where available.

On this webcast, our panelists will discuss key considerations for US companies, focusing on areas of tension between the US Section 482 regulations and the new OECD guidance. The panelists will also discuss recent global audit activity in financial transactions and the current state of financial markets in the COVID-19 environment.

Additional topics will include:

  • Intra-group lenders without functional substance
  • Actual delineation of the transaction:
    • Guaranteed loans
    • Terms of funding
  • "Options realistically available" analysis
  • Cash pools
  • Credit rating
  • Local implementation

Date: Thursday, 28 May 2020

Time: 1:00-2:15 p.m. EDT New York/Toronto; 10:00-11:15 a.m. PDT Los Angeles/Vancouver

Registration: Register for this event.


  • Sayantani Ghose, Partner, Financial Services Office, Ernst & Young LLP
  • Tom Gottfried, Senior Manager, Transfer Pricing, Ernst & Young LLP
  • John Hill, Senior Manager, Transfer Pricing, Ernst & Young LLP
  • Abraham Isgur, Senior Manager, Financial Services Office, Ernst & Young LLP
  • Nikhil Jain, Partner, Financial Services Office, Ernst & Young LLP


  • Mike McDonald, Managing Director, Transfer Pricing, Ernst & Young LLP

CPE credit offered: 1.5. Recommended field of study: Taxes. Learning objective: Understand the implications for US companies of OECD Transfer Pricing Guidelines on Financial Transactions. This intermediate level, group internet-based course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.

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