Released on the Cutts Watson website on 15th January 2021 The OECD ‘Transfer Pricing Guidance on Financial Transactions’ Report in February 2020 raises a justification for captives that is unrelated to tax i.e. in managing intra-group risks in a more economically feasible way than that provided by the conventional insurance market. However, from a corporate… Continue reading DAC 6: Captives in Murky Water