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Intragroup Financing Under Scrutiny: Why Now and What You Can Do to Ensure Compliance

February 12, 2026 11:00am ET

Join us for an in-depth exploration of transfer pricing for financial transactions—one of the most scrutinized areas in international tax today. This session will cover the fundamentals of intra-group financing, the regulatory landscape shaped by OECD Chapter X, and the latest case law demonstrating how tax authorities worldwide are challenging interest deductions and recharacterizing transactions. You’ll gain practical insights into managing risk, strengthening documentation, and aligning your financial transactions with both commercial realities and compliance requirements.

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Understand the key types of financial transactions (loans, cash pooling, guarantees, captive insurance, hedging) and the transfer pricing challenges they present under current OECD guidance.

Analyze recent regulatory developments and landmark cases to recognize how tax authorities are shifting from pricing-focused audits to substance-based scrutiny of intra-group financing.

Apply best practices for accurate delineation, debt capacity analysis, and documentation to mitigate transfer pricing risk and strengthen your organization's compliance posture.

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Speakers

Mili Diaz Colodrero

VP of Transfer Pricing

Transfer pricing leader with a strong background in managing high-performing, global teams within the TP software space. While my expertise covers several areas of TP, from compliance to controversy support, policy assessment and financial transactions, my day-to-day is about people: guiding teams, building collaboration, and making sure we deliver real value to our clients. Over the past few years, I’ve had the opportunity to manage diverse teams across regions, helping multinational clients strengthen their TP governance and use technology to work smarter and more efficiently. I’m passionate about developing talent, creating clarity amid complexity, and fostering a culture of accountability and excellence.

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