Even though the OECD BEPS project has addressed numerous issues in the Final Reports published in October 2015, the transfer pricing aspects of financial transactions within MNE, to a main extent, have not been specifically covered by the scope of these reports. What is more, this topic was also only partially dealt with in the pre-BEPS OECD Transfer Pricing Guidelines. However, the lack of extensive guidance on financial transactions is intended to be addressed by the current work of the OECD. The OECD published a discussion draft in July 2018 (in the following: DD 2018) in order to lead a public discourse on this topic.
