TREASURY OPERATIONS AND TRANSFERT PRICING

Parution : juillet 2009

PRESENTATION

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.
This technical guide looks to explain some of the General Principles of Transfer Pricing and links those principles to the treasury operations. In addition we have added appendix 1 which looks at more general transfer pricing issues for goods and services.

SOMMAIRE

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