The End of Intra-Group Financing... or Not Just Yet? – Part 1

This article examines, first, how the outcome of the OECD BEPS Project will impact numerous aspects of intra-group financing as multinationals currently know it, serving as a roadmap for the reader to navigate through the jungle of rules considered and proposed by the OECD. At the same time, the authors are critical of the OECD’s proposals and analyse the extent to which they might result in collateral damage for the funding of group or business investment in general. Part 1 addresses the borrower’s perspective, while Part 2, to be published in European Taxation 8 (2015), analyses the lender’s perspective.