Conceptual framework for determining the transfer price of loans

Conceptual framework for determining the transfer price of loans

Článek WoS

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.

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.

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.

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.

KALOVÁ, D.

2024

08.08.2023

Magnanimitas

The Czech Republic, Hradec Králové

2464-6733

AD ALTA: Journal of Interdisciplinary Research

13

1

Česká republika

140

145

6

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