Please use this identifier to cite or link to this item: https://hdl.handle.net/10419/329826 
Year of Publication: 
2022
Citation: 
[Journal:] Financial Internet Quarterly [ISSN:] 2719-3454 [Volume:] 18 [Issue:] 4 [Year:] 2022 [Pages:] 23-34
Publisher: 
Sciendo, Warsaw
Abstract: 
The OECD project against BEPS has brought and initiated many changes - among others, in the OECD Transfer Pricing Guidelines. To react and respond to changes in the current business environment, a new chapter for transfer pricing in financial transactions has also been introduced (namely chapter X). This step can be considered beneficial. However, meeting all the requirements for setting a transfer price for financial transactions seems to remain a very demanding and expensive task. Furthermore, the OECD Transfer Pricing Guidelines have been of a general nature rather than providing responses to all potential problems and circumstances - they provide fundamental ideas and principles. Thus, the potential to apply a simplified procedure for setting a transfer price (even for financial transactions) can be viewed as desirable, both for taxpayers and tax authorities. The aim of the paper is linked to this idea - to present the results of a comparative study dealing with the rules for safe harbours for financial transactions (namely loans) as established worldwide, providing a summary of existing concepts and systematized criteria for a safe harbour to be considered.
Subjects: 
Comparative Study
Financial Transaction
Loan
Safe Harbour
Transfer Pricing
JEL: 
H25
K34
Persistent Identifier of the first edition: 
Creative Commons License: 
cc-by-nc-nd Logo
Document Type: 
Article

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