TREASURY OPERATIONS AND TRANSFERT PRICING Parution : juillet 2009
The role of the corporate
treasurer has evolved over the past 15 years from dealing with cash
management to setting and applying group funding policies. Therefore the
Corporate Treasurer is in the perfect position to set the group transfer
pricing policy for Treasury operations and support the documentation of the
group policies.
INTRODUCTION 1. BASIC PRINCIPLES 2. ILLUSTRATION
OF THE APPLICATION BY TAX AUTHORITIES OF THESE BASIC
PRINCIPLES 3.
DOCUMENTATION 4. VALUE CHAIN OF THE
TREASURY FUNCTION AND ITS LINK TO TRANSFER PRICING 5. FUNCTIONAL
ANALYSIS OF THE BUSINESS 6. OECD
PRICING METHODOLOGIES 7. PRACTICAL
PRICING 8. APA'S AND
PENALTIES & SOLUTIONS 9. THIN
CAPITALIZATION APPENDIX SUMMARY |