New transfer pricing guidance on financial transactions
On 11 February 2020 the OECD released its final transfer pricing guidance on financial transactions. The new guidance provides recommendations regarding the application of the arm’s length principle to financial transactions and addresses the pricing of intra-group loans, cash pooling, guarantees and captive insurance premiums.
On 26 March 2021, the European Commission (the “Commission”) published “Commission Guidance on the application of the referral mechanism set out in Article 22 of the Merger Regulation to certain categories of cases”.1
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