CAHIERS TECHNIQUES
(Publication de l'AFTE)
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
|