How to price intragroup financial transactions?

A new chapter on intra-group financial transactions has been introduced into the OECD Transfer Pricing Guidelines. These guidelines are long overdue for transfer pricing practitioners, but the impact of these guidelines should be felt by tax and non-tax professionals alike in a range of day-to-day and one-off financial transactions between group entities, including the provision of loans and funding facilities, provision of guarantees, treasury operations and hedging activities performed by one group entity for other group entities, cash pooling arrangements, transfers of receivables or loan balances and so on. How do you ensure that these financial transactions between group entities are carried out under terms that are consistent with the arm’s length principle? Are there practical approaches that can be useful as a guide for non-tax treasury colleagues? What are some of the common pitfalls that should be avoided?


Topics Covered

Block 1: Intra-Group Financial Transactions and the Arm’s Length Principle

  • Different types of financial transactions
  • Impact of the application of the arm’s length principle

Block 2: Practical Tips

  • Potential areas of disputes - e.g. debt vs equity, implicit support, establishing comparables, transfers at arm’s length vs book value, etc.
  • Some do’s and don’ts in pricing intra-group financial transactions

Block 3: Recent cases

  • Selected cases and what can be learned from them
  • Assessing the anticipated impact on multinational groups

Learning Objectives

After this webinar, the participants will be able to: 

  • Identify the areas in the OECD Transfer Pricing Guidelines on Financial Transactions that are most likely to be associated with cross-border disputes
  • Define the key challenges that MNEs face in setting the arm’s length price for intra-group financial transactions
  • Assess the pragmatic approaches that may be used in treasury operations and recommend changes to conform with the arm’s length principle; and
  • Assess the impact of the latest case law concerning the transfer pricing of intra-group financial transactions.


Shee Boon Law

Rachit Agarwal

Field of study


Who should participate

In-house tax professionals and advisers looking to understand transfer pricing aspects in intra-group financial transactions within a multinational group - Legal professionals assessing the compliance risk associated with the application of Chapter X of the OECD Transfer Pricing Guidelines, how to comply with the associated rules and manage the potential controversy risk associated with these rules - Government officials engaging in the audit and enforcement of transfer pricing requirements in intra-group transactions involving financial transactions

Course level and prerequisites

This is an intermediate-level webinar. Participants in this webinar are expected to have at least 3 to 5 years of experience in international tax and to be familiar with the key concepts of international tax law.

Advance preparation

No advance preparation is needed. Participants are expected to be familiar with the key concepts of international tax law.

Interactive webinar – “Group Internet Based” (live webinar only)

During live webinars, it is possible to interact with the presenters via a chat message function. Please note that questions are answered based on relevance, order of receipt and available time. Additionally, participants in the live webinar are invited to answer poll questions. Participants will also have access to the on-demand version for a further 12 months from the live date.

Date of live broadcast:26 March 2024

On-demand webinar

On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation nor do they offer the assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months.

Continuing Professional Education

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Webinar registration details

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