Publication detail

Conceptual framework for determining the transfer price of loans

KALOVÁ, D.

Original Title

Conceptual framework for determining the transfer price of loans

Type

journal article in Web of Science

Language

English

Original Abstract

Associated enterprises integrated into business groups may use the capital resources of the group. When setting the remuneration for their use, they must ensure that prices between them are set according to the rules of the Organisation for Economic Co-operation and Development (OECD). The core document is the Transfer Pricing Guidance on Financial Transactions. Based on the results of a qualitative analysis (content and contextual analysis of the document), the aim of the article is to systematize the procedures used to determine the transfer price in financial transactions such as loans and borrowings where the parties are related parties (hereinafter referred to as "intra-group loans"). The decision-making process is illustrated by means of a flow chart that establishes the basic decision framework, or the individual steps leading to the selection of an appropriate transfer pricing method for intra-group loans.

Keywords

Associated enterprises integrated into business groups may use the capital resources of the group. When setting the remuneration for their use, they must ensure that prices between them are set according to the rules of the Organisation for Economic Co-operation and Development (OECD). The core document is the Transfer Pricing Guidance on Financial Transactions. Based on the results of a qualitative analysis (content and contextual analysis of the document), the aim of the article is to systematize the procedures used to determine the transfer price in financial transactions such as loans and borrowings where the parties are related parties (hereinafter referred to as "intra-group loans"). The decision-making process is illustrated by means of a flow chart that establishes the basic decision framework, or the individual steps leading to the selection of an appropriate transfer pricing method for intra-group loans.

Authors

KALOVÁ, D.

Released

8. 8. 2023

Publisher

Magnanimitas

Location

The Czech Republic, Hradec Králové

ISBN

2464-6733

Periodical

AD ALTA: Journal of Interdisciplinary Research

Year of study

13

Number

1

State

Czech Republic

Pages from

140

Pages to

145

Pages count

6

URL

https://www.magnanimitas.cz/ADALTA/1301/papers/A_kalova.pdf

BibTex

@article{BUT184030,
  author="Dagmar {Kalová}",
  title="Conceptual framework for determining the transfer price of loans",
  journal="AD ALTA: Journal of Interdisciplinary Research",
  year="2023",
  volume="13",
  number="1",
  pages="140--145",
  issn="2464-6733",
  url="https://www.magnanimitas.cz/ADALTA/1301/papers/A_kalova.pdf"
}