Additional guidance is still to be provided in order to fully clarify the transfer pricing issues related to financial transactions

The newly released public Discussion Draft “BEPS ACTIONS 8 – 10, Financial transactions” (the “Discussion Draft”) provides additional guidance to taxpayers and tax administrations on how to deal with controlled financial transactions.

Particular focus has been devoted to the accurate delineation of the financial transaction under Chapter I, as well as to the pricing of specific financial transactions.

Our concerns can be considered in four groups:

 We provided our comments on 07 September 2018