Transfer Pricing: Accurate Delineation of the Captive Insurance Arrangement – Is the OECD Guidance Clear on this Matter?
Introduction Recently captive insurance arrangements have been scrutinized all over the world by tax authorities as they are believed to be vehicles that encourage profit shifting. The OECD, in the BEPS Action Plan, had considered captive insurance arrangements as a major area of concern. In fact, in the recently released 2018 OECD discussion draft on…