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Cross-border financing arrangements - The release of long-awaited consensus guidance paper

Published on 15 Sep 20 by NATIONAL DIVISION, THE TAX INSTITUTE

This paper covers:

  • the pricing framework in the OECD FT paper
  • case study - how do I price an intercompany financing arrangement?
  • the importance of contemporaneous documentation and evidence.

Author profiles

Edwin Baghdasarayan ATI
Edwin is a Transfer Pricing Partner within the PwC Australia Global Tax practice, based in Sydney. He has practiced transfer pricing at PwC since 2007 and has been involved in assisting numerous Australian, US and NZ top listed multinationals in their global transfer pricing across the entire lifecycle including consulting, structuring and planning, documentation, managing risk reviews, audits and unilateral/bilateral APAs. His experience ranges across a variety of industries, including financial services, consumer & industrial products, resources, logistics/transport and the technology sector. In particular, he has extensive experience in transfer pricing consulting for financial transactions, including funding across various industries and corporate purposes, financial instruments (e.g., options, swaps & forwards), cash pooling, guarantee fees and thin capitalisation/debt characterisation. As part of this experience, he has actively contributed to financial transactions transfer pricing thought leadership within both the US and the Asia Pacific region including drafting publications, leading presentations and various other policy initiatives. - Current at 22 October 2020
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Mattia Capsoni

 

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