PEP session: Intercompany financial transactions – a tax and transfer pricing update

Intercompany financial transactions often play a key role within the funding structures of Multinational groups, and tax (especially transfer pricing) are increasingly becoming an essential consideration in structuring such transactions. 

During this PE seminar tax and transfer pricing experts from PwC will go into some key Dutch, EU and global developments with respect to intercompany financial transactions, such as the recent guidelines from the OECD on how to price and substantiate intercompany financial transactions, the incorporation thereof in the recently updated Dutch transfer pricing decree, but also into broader tax developments such as the application of the earning stripping rules and developments around Pillar II (OECD initiative to achieve a global minimum tax rate of 15%), ATAD III (EU rules on substance cq shell companies) and how these developments can be relevant for intercompany financial transactions. 

The PE seminar is especially of interest for treasurers operating in a crossborder environment and who need to understand and appreciate the basic principles and potential impact for their daily work resulting from these guidelines and developments  “Should I perform a credit rating analysis for my subsidiaries when pricing a loan” (yes!), “Can I use bank quotes to price a loan” (no!), “Should I also consider guarantees and/or cross collaterals in relation to external funding” (yes!), “Is substance important for deductibility/taxation of interest income” (yes!). 

During this interactive PE seminar these and many other relevant and practical questions will be discussed by the following experts from PwC. 

In order to make most out of this session you are welcome to take a tax colleague with you to this session. 

The session will be hosted in English. 

Workshop leaders are: 

Michel van der Breggen, transfer pricing partner specialised in intercompany financial transactions and former board member of the DACT. 

Neil Schaatsbergen, transfer pricing director specialised in intercompany financial transactions. 

Pieter Ruige, corporate tax senior manager specialised in intercompany financial transactions and interest deduction limitation rules. 

When & where: 

Tuesday 22 November from 9.30-12.00. 

PwC Offices in Amsterdam 

Registration is closed.