The application of arm’s length principle (ALP) to intra-group Financial Transactions (FT) has been an intricate and contentious issue for multinational enterprises (MNE) in recent years. Recently, two of the big intergovernmental organizations, Organisation for Economic Cooperation and Development (OECD) and the United Nations (UN) released a series of proposals (in July 2018 by OECD and on 08 April 2019 by UN) with respect to FT.
Nitin Narang, Partner and Adarsh Rathi, Director- Transfer Pricing & International Tax contributed an piece on UN Draft Guidance on Financial Transactions – A Welcome Move for Tax sutra
