Full Text Available
Note: Clicking the button above will open the full text document at the original institutional repository in a new window.
Global trading and transfer pricing: application of the transfer pricing methods and OECD BEPS Action Plan 9 to global trading of financial instruments by MNE groups in the financial services sector
This dissertation focuses on the Organisation for Economic Co-operation and Development ('OECD') transfer pricing methods and its application to Multinational Enterprise ('MNE') groups in the financial sector. This study examines whether the OECD's Base Erosion and Profit Shifting ('BEPS') Action Pl...
Saved in:
| Main Author: | |
|---|---|
| Other Authors: | |
| Format: | Thesis |
| Language: | English |
| Published: |
Department of Finance and Tax
2018
|
| Subjects: | |
| Tags: |
No Tags, Be the first to tag this record!
|
| _version_ | 1867613219254697984 |
|---|---|
| access_status_str | Open Access |
| author | Joseph, Arlene |
| author2 | West, Craig |
| author_browse | Joseph, Arlene West, Craig |
| author_facet | West, Craig Joseph, Arlene |
| author_sort | Joseph, Arlene |
| collection | Thesis |
| description | This dissertation focuses on the Organisation for Economic Co-operation and Development ('OECD') transfer pricing methods and its application to Multinational Enterprise ('MNE') groups in the financial sector. This study examines whether the OECD's Base Erosion and Profit Shifting ('BEPS') Action Plan 9 is an appropriate framework for MNE groups in the banking sector or whether it creates further challenges. Additionally, the dissertation scrutinises MNE groups in the financial sector that are involved in the business of global trading of financial instruments. It further explores the functions of a global trading entity, the arm's length principle and the OECD BEPS Action Plan 9. This dissertation concludes that the global trading of financial instruments using the integrated trading model is challenged when the OECD traditional transfer pricing methods are applied. Multinational financial institution groups in the banking sector that are involved in the business of global trading of financial instruments are subject to rigid regulations. Furthermore, the report concludes that these rigid regulations mitigate some of the complications that arise when applying the OECD BEPS Action Plan 9. Taxing authorities need to focus greater attention on the global trading of financial instruments by multinational financial institutions groups. As South Africa's financial institutions expand across borders, the concerns over transfer pricing and BEPS are likely to intensify. It is therefore imperative that the South African revenue authorities prioritise the recruitment of skilled personnel in order to address the complexities posed by the global trading of financial instruments by multinational financial institution groups. |
| format | Thesis |
| id | oai:open.uct.ac.za:11427/26956 |
| institution | University of Cape Town (South Africa) |
| language | eng |
| last_indexed | 2026-06-10T12:32:39.476Z |
| license_str | Not specified — see source repository |
| provenance_str_mv | Harvested via OAI-PMH from UCTD — University of Cape Town Open Access Repository |
| publishDate | 2018 |
| publishDateRange | 2018 |
| publishDateSort | 2018 |
| publisher | Department of Finance and Tax |
| publisherStr | Department of Finance and Tax |
| record_format | dspace |
| source_str | UCTD — University of Cape Town Open Access Repository |
| spelling | oai:open.uct.ac.za:11427/26956 Global trading and transfer pricing: application of the transfer pricing methods and OECD BEPS Action Plan 9 to global trading of financial instruments by MNE groups in the financial services sector Joseph, Arlene West, Craig Financial Instruments Financial Services Sector This dissertation focuses on the Organisation for Economic Co-operation and Development ('OECD') transfer pricing methods and its application to Multinational Enterprise ('MNE') groups in the financial sector. This study examines whether the OECD's Base Erosion and Profit Shifting ('BEPS') Action Plan 9 is an appropriate framework for MNE groups in the banking sector or whether it creates further challenges. Additionally, the dissertation scrutinises MNE groups in the financial sector that are involved in the business of global trading of financial instruments. It further explores the functions of a global trading entity, the arm's length principle and the OECD BEPS Action Plan 9. This dissertation concludes that the global trading of financial instruments using the integrated trading model is challenged when the OECD traditional transfer pricing methods are applied. Multinational financial institution groups in the banking sector that are involved in the business of global trading of financial instruments are subject to rigid regulations. Furthermore, the report concludes that these rigid regulations mitigate some of the complications that arise when applying the OECD BEPS Action Plan 9. Taxing authorities need to focus greater attention on the global trading of financial instruments by multinational financial institutions groups. As South Africa's financial institutions expand across borders, the concerns over transfer pricing and BEPS are likely to intensify. It is therefore imperative that the South African revenue authorities prioritise the recruitment of skilled personnel in order to address the complexities posed by the global trading of financial instruments by multinational financial institution groups. 2018-01-25T06:43:39Z 2018-01-25T06:43:39Z 2017 Master Thesis Masters MCom http://hdl.handle.net/11427/26956 eng application/pdf Department of Finance and Tax Faculty of Commerce University of Cape Town |
| spellingShingle | Financial Instruments Financial Services Sector Joseph, Arlene Global trading and transfer pricing: application of the transfer pricing methods and OECD BEPS Action Plan 9 to global trading of financial instruments by MNE groups in the financial services sector |
| thesis_degree_str | Master's |
| title | Global trading and transfer pricing: application of the transfer pricing methods and OECD BEPS Action Plan 9 to global trading of financial instruments by MNE groups in the financial services sector |
| title_full | Global trading and transfer pricing: application of the transfer pricing methods and OECD BEPS Action Plan 9 to global trading of financial instruments by MNE groups in the financial services sector |
| title_fullStr | Global trading and transfer pricing: application of the transfer pricing methods and OECD BEPS Action Plan 9 to global trading of financial instruments by MNE groups in the financial services sector |
| title_full_unstemmed | Global trading and transfer pricing: application of the transfer pricing methods and OECD BEPS Action Plan 9 to global trading of financial instruments by MNE groups in the financial services sector |
| title_short | Global trading and transfer pricing: application of the transfer pricing methods and OECD BEPS Action Plan 9 to global trading of financial instruments by MNE groups in the financial services sector |
| title_sort | global trading and transfer pricing application of the transfer pricing methods and oecd beps action plan 9 to global trading of financial instruments by mne groups in the financial services sector |
| topic | Financial Instruments Financial Services Sector |
| url | http://hdl.handle.net/11427/26956 |
| work_keys_str_mv | AT josepharlene globaltradingandtransferpricingapplicationofthetransferpricingmethodsandoecdbepsactionplan9toglobaltradingoffinancialinstrumentsbymnegroupsinthefinancialservicessector |