So – finally! After a couple of years waiting, the work within the OECD BEPS project on transfer pricing of financial transactions has been published. I must admit, with a heightened sense of anticipation, I was disappointed. I had expected (after two years) answers to it all. On the other hand, since the public discussion draft is a collection of questions rather than answers, it gives the public the opportunity to provide thoughts and comments that are (one hopes) based on experience and real life examples. From a personal perspective, I am very passionate about transfer pricing of financial transactions. The comments below are based on my experience in this area which covers almost ten years, both as a tax advisor to banks and industrial groups as well as an in-house expert within a banking group. It is important to point out that, unless clearly stated otherwise, my comments are related to financial transactions within industrial groups. Only the third chapter deals specifically with intra-group funding within a banking group.