驾驭波动：在新型重商主义格局下管理转让定价和公司间借贷

Core Viewpoint - The article discusses the significant transformation in the global tax landscape for multinational corporations driven by regulatory changes and geopolitical shifts, emphasizing the need for strategic considerations in managing intercompany financing arrangements [2][3][15]. Group 1: Economic Nationalism and Tax Implications - The post-pandemic world has seen a shift from globalization to economic nationalism, with major economies implementing policies to bring key industries back home and protect domestic tax bases [3]. - Tax authorities are increasingly scrutinizing the commercial rationale behind intercompany financing structures, especially those involving low-tax jurisdictions, leading to potential double taxation risks [3][5]. - Governments are restricting the cross-border flow of critical intellectual property and technology, impacting transfer pricing models based on intellectual property licensing [3][5]. Group 2: BEPS 2.0 and Its Impact - The OECD's Base Erosion and Profit Shifting (BEPS) initiative has evolved into "BEPS 2.0," fundamentally reshaping international taxation with two main pillars [4][6]. - Pillar One reallocates taxing rights to the market jurisdiction where customers are located, challenging traditional profit allocation to low-tax jurisdictions [6]. - Pillar Two establishes a global minimum corporate tax rate of 15%, limiting the benefits of profit shifting to low-tax jurisdictions and necessitating a reevaluation of existing financial structures [6][7]. Group 3: Complexity in Transfer Pricing and Intercompany Lending - The requirements for intercompany lending and transfer pricing documentation have become increasingly complex, necessitating comprehensive functional analyses and market-based justifications for interest rates [8]. - Companies must adopt rigorous methods to withstand stricter scrutiny, including objective credit rating assessments and consideration of local market conditions [8][11]. Group 4: Strategic Recommendations for Financial and Tax Teams - Financing structures should reflect the actual business activities and value creation locations rather than merely focusing on tax rate advantages [13]. - A reassessment of centralized financing models is recommended, considering a distributed approach that aligns better with operational layouts [13]. - Companies should maintain comprehensive documentation to demonstrate the economic substance of their financing arrangements and proactively model the impacts of proposed tax reforms [13][15].