The OECD’s and G20’s BEPS Action Plan identified the key principles that underlie the taxation of cross-border activities and the BEPS opportunities these principles may create. Financial transactions have been a key area of concern since the beginning of the project. In particular, transfer pricing aspects of financial transactions have been dealt with in BEPS actions 8–10 (“Aligning Transfer Pricing Outcomes with Value Creation") and in BEPS action 4 (“Limiting Base Erosion Involving Interest Deductions and Other Financial Payments"). However, financial transactions have recently gained momentum with the long-awaited OECD report on transfer pricing of financial transactions.
