OECD Finishes Tech Work On Financial Transaction Guidance

Law360, Washington (June 5, 2019, 8:17 PM EDT) -- The Organization for Economic Cooperation and Development has finished technical work on its transfer pricing guidance for financial transactions, with one of the group's working parties refining commentary on an issue involving companies’ capital structure, an OECD official said.

Working Party 1, which deals with tax treaties, is discussing whether the arm’s-length standard, set forth in Article 9 of the OECD Model Tax Convention, a template for treaties, applies to companies’ capital structures — how much is financed with debt versus equity. There have been “fundamentally different views” on that issue, Tomas Balco, head of the organization’s transfer pricing unit, said...

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