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International - Transfer Pricing Aspects of Intra-Group Financial Guarantees in Light of the BEPS Action Plan

V. Averyanova; J. Sampat
International Transfer Pricing Journal, 2015 (Volume 22), No 6
15 October 2015
The main objective of this article is to provide an overview of the transfer pricing aspects of intra-group financial guarantees. It discusses the current approach to the determination of the arm’s length level of the guarantee fee outlined in the OECD Guidelines and the Canadian court case General Electric. The article analyses the approach proposed in the 2014 Deliverable on Action 8 of the BEPS Action Plan “Guidance on TP Aspects of Intangibles”, including its compatibility with the authoritative statement of the arm’s length principle, as well as the practical considerations in the post-BEPS environment and the potential suggestions for further improvements to be made to the OECD Guidelines.
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