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TPI 2, April 2020, Seite 59

Challenges Ahead for the Financial Services Sector on Technological and Regulatory Change

Florian Henninger und Mirna S. Screpante

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.

Considering that the global tax law landscape is changing considerably, it is important to highlight the impact of these changes on the technological and the regulatory aspects in the financial services sector. With this aim, academics, practitioners, and tax advisors from various countries attended the first Financial Services Transfer Pricing Conference held at Deloitte Vienna on January 20th, 2020, to discuss the most relevant transfer pricing topics affecting the financial services sector.

1. Current Challe...

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