Challenges in transfer pricing: A concept of safe harbours for financial transactions
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Date
2022-11-14
Authors
Ištok, Michal
Solilová, Veronika
Brychta, Karel
ORCID
0000-0002-9184-1598Advisor
Referee
Mark
Journal Title
Journal ISSN
Volume Title
Publisher
University of Information Technology and Management in Rzeszow
Altmetrics
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.
Description
Citation
Financial Internet Quaterly. 2022, vol. 18, issue 4, p. 23-34.
https://finquarterly.com/current-issue/?number=75&id=582
https://finquarterly.com/current-issue/?number=75&id=582
Document type
Peer-reviewed
Document version
Published version
Date of access to the full text
Language of document
en
Study field
Comittee
Date of acceptance
Defence
Result of defence
Document licence
Creative Commons Attribution-NonCommercial-NoDerivatives 3.0 Unported
http://creativecommons.org/licenses/by-nc-nd/3.0/
http://creativecommons.org/licenses/by-nc-nd/3.0/