Pricing Intercompany Financial Transactions: Loans, Guarantees and Cash-Pooling Arrangements

This article analyses the OECD discussion draft on financial transactions dealing with the application of the arm’s length principle to financial transactions. In this respect, the article describes how to accurately delineate financial transactions, such as intercompany loans, guarantees and cash-pooling arrangements, and provides an overview of how to price these financial transactions in accordance with the arm’s length principle.