The Dutch tax authority prevailed in its challenge of several British American Tobacco intercompany financing transactions.

Topics: Intercompany Financing Intercompany Guarantee Fees Arm's Length Interest Rates Intercompany Loans

Harold McClure expounds on the issue of currency denomination in intercompany financing, addressing currency adjustments in longer-term fixed interest rates, past controversies, and regulatory guidance.

Topics: Financial Transactions OECD United Nations Adjustments Intercompany Financing Arm's Length Interest Rates

One of the most challenging transfer pricing issues regarding financial transactions is making a comparability adjustment for differences in country risk between the tested non-US borrower’s country and the comparable US borrower's country in pricing the intercompany loan interest rate.

Topics: CUFT State Transfer Pricing Adjustments Intercompany Financing Arm's Length Interest Rates

Intercompany financing is a growing area of focus in transfer pricing. CUFT Analytics co-founder and managing director John Hollas provides guidance on using the EdgarStat CUFT Loan Agreements Database to benchmark an arm's length range of interest rates.

Topics: CUFT Credit Risk Intercompany Financing Arm's Length Interest Rates