Publication detail

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

IŠTOK, M. SOLILOVÁ, V. BRYCHTA, K.

Original Title

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

Type

journal article in Web of Science

Language

English

Original 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

Authors

IŠTOK, M.; SOLILOVÁ, V.; BRYCHTA, K.

Released

14. 11. 2022

Publisher

University of Information Technology and Management in Rzeszow

Location

Rzeszow, Poland

ISBN

2719-3454

Periodical

Financial Internet Quaterly

Year of study

18

Number

4

State

Republic of Poland

Pages from

23

Pages to

34

Pages count

12

URL

https://finquarterly.com/current-issue/?number=75&id=582

Full text in the Digital Library

http://hdl.handle.net/11012/209114

BibTex

@article{BUT182377,
  author="Michal {Ištok} and Veronika {Solilová} and Karel {Brychta}",
  title="Challenges in transfer pricing: A concept of safe harbours for financial transactions",
  journal="Financial Internet Quaterly",
  year="2022",
  volume="18",
  number="4",
  pages="23--34",
  doi="10.2478/fiqf-2022-0025",
  issn="2719-3454",
  url="https://finquarterly.com/current-issue/?number=75&id=582"
}

Documents

3. Brychta.pdf