Challenges in transfer pricing: A concept of safe harbours for financial transactions

Ištok Michal (), Solilová Veronika () and Brychta Karel ()
Additional contact information
Ištok Michal: Brno University of Technology, Faculty of Business and Management; Matej Bel University in Banská Bystrica, Czech Republic
Solilová Veronika: Brno University of Technology, Faculty of Business and Management; Mendel University in Brno, Czech Republic
Brychta Karel: Brno University of Technology, Faculty of Business and Management, Czech Republic

Financial Internet Quarterly (formerly e-Finanse), 2022, vol. 18, issue 4, 23-34

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.

Keywords: comparative study; financial transaction; loan; safe harbour; transfer pricing (search for similar items in EconPapers)
JEL-codes: H25 K34 (search for similar items in EconPapers)
Date: 2022
References: Add references at CitEc
Citations:

Downloads: (external link)
https://doi.org/10.2478/fiqf-2022-0025 (text/html)

Related works:
This item may be available elsewhere in EconPapers: Search for items with the same title.

Export reference: BibTeX RIS (EndNote, ProCite, RefMan) HTML/Text

Persistent link: https://EconPapers.repec.org/RePEc:vrs:finiqu:v:18:y:2022:i:4:p:23-34:n:8

DOI: 10.2478/fiqf-2022-0025

Access Statistics for this article

Financial Internet Quarterly (formerly e-Finanse) is currently edited by Tomasz Skica

More articles in Financial Internet Quarterly (formerly e-Finanse) from Sciendo
Bibliographic data for series maintained by Peter Golla ().