Comments sent to OECD on BEPS Actions 8, 9 and 10

6 February 2015

On 6 February, GFIA sent comments to the Organisation for Economic Co-operation and Development (OECD) on the discussion draft on revisions to Chapter I of the Transfer Pricing Guidelines (action points 8, 9 and 10).


In the response, GFIA welcomes the guidance from the OECD, but makes a number of comments raising concerns about the fact that some of the actions proposed do not apply to the insurance industry. GFIA also emphasised that – for an insurer – maintaining an appropriate level of capital within a jurisdiction is not a business choice, open to flexibility depending on the tax treatment of debt but instead it is critical to an insurer’s ability to carry on business.

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