Financial Services Transfer Pricing:

Changing landscapes

A collection of articles and insights inspired by a range of relevant topics including OECD BEPS initiatives, Brexit, tax audit trends as well as key market and regulatory developments.

Deloitte's Financial Services Transfer Pricing global publication

In this edition, the article series starts by exploring recent trends in the asset management sector covering transfer pricing methodologies/models for the sector as well as a discussion of the transfer pricing dimension of the unique role of regulated management companies under the Undertakings for the Collective Investment of Transferable Securities ("UCITS") and the Alternative Investment Fund Managers Directive ("AIFMD") regimes. The next two articles focus on the banking sector and examine two key issues related to branch capital attribution and funds transfer pricing which both are gaining more importance in light of a changing regulatory environment. Key trends in the insurance sector with respect to profit attribution and the developments on key entrepreneurial risk Taking ("KERT") functions in light of BEPS is the focus of the next article. Given that the countdown has started to the departure of the UK from the European Union, an update on transfer pricing ramifications based on how the financial services sector is currently addressing this key event and related uncertainty is also included. Finally, we detail the key points covered in the OECD Discussion Draft on Transfer Pricing of financial transactions.

This publication is intended to be informative. Feel free to reach out to the listed Deloitte Financial Services Transfer Pricing team contacts for more information or in case of any questions.

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