Intercompany Financing insights: BEPS Oriented and during a Crisis period

June 3, 2020

The OECD’s publication on Financial Transactions addresses the Report on Actions 8-10 of the BEPS Action Plan, which includes transfer pricing guidance for related party financial transactions. The goal of this webinar is to identify some major aspects applicable to determining and supporting the arm’s length nature of intercompany financing transactions (including the terms of the instrument and the pricing of the transaction) on an on-going basis and in a crisis period like the COVID-19 outbreak.

With this objective in mind, TPA Global invites you to an informative webinar where we will discuss the practical aspects and experience on the following topics:

Part I – Methodological Overview

A general introduction regarding TP in the time of COVID-19 and the OECD’s recent publication on financial transactions.
During this part we will address the following items:

  • TP Models;
  • Benchmarks Implications;
  • Arm’s length interquartile ranges implications;
  • Comparison to 3rd parties’ arrangements during a crisis period;
  • Intercompany finance transactions during a crisis period.
Part II – Earning Striping the Right Way – Illustrative examples
  • Intercompany Mezzanine Loan
  • Intercompany Factoring Transaction
  • Adv. (Eco.) Yariv Ben Dov, YBD Transfer Pricing Services – a member of TPA Global
  • Marina Menezes da Silva Associate at TPA Global
  • Dana Umarkulova, Associate at TPA Global

TPA Global

H.J.E Wenckebachweg 210
1096 AS Amsterdam