The UN released an updated draft on financial transactions in April 2019, which in addition to the discussion draft released by OECD in 2018, provides guidance on the disputes in transfer pricing issues. Here we compare the two drafts and advanced domestic practices (i.e. the UK and Australia).
When comparing different key variables to determine (i) an acceptable D/E level; (ii) an acceptable interest rate (includes guarantee fees), OECD draft, UN draft, UK legislation, Australian legislation require the following checks:
Click on the button below for the detailed schedule TPA Global uses for the creation, implementation, and documentation of TP systems for Treasury activities.