Blog

The EdgarStat Blog explores issues in transfer pricing and application of the transactional net margin method (TNMM or CPM in the US) and other enterprise profit-based methods.

Dutch Tax Authority Wins Challenge of British American Tobacco's Intercompany Financing
November 10, 2022 by Harold McClure

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

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

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Fixed-Rate Intercompany Loans and Currency Denomination
September 12, 2022 by Harold McClure

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

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Tutorial: Currency Adjustments in Intercompany Financing
August 03, 2022 by John Hollas

In this tutorial, we address comparability adjustments for differences in the currency of the tested loan to that of the comparable transactions.

Topics: Interest Rates Tutorial CUFT Financial Transactions Intercompany Financing

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Tutorial: Country Risk Adjustment in Intercompany Financing
May 26, 2022 by John Hollas

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

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Tutorial: Estimating Implied Credit Rating Using Altman Z"-Score Tool
November 05, 2021 by John Hollas

In this tutorial we introduce you to a tool in the EdgarStat CUFT Loan Agreements Database for estimating the implied credit rating of your tested borrower using the Altman Z”-Score Model.

Topics: Credit Rating CUFT Intercompany Financing

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Tutorial: Benchmarking with the CUFT Loan Agreements Database in EdgarStat
September 28, 2021 by John Hollas

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

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Benchmarking Intercompany Loans: Market Conditions Matter
September 08, 2021 by Harold McClure

Interests fluctuate based on market conditions, and analysts must consider whether the market conditions surrounding their data are comparable to those of the tested intercompany transaction when benchmarking an arm's length interest rate in transfer pricing.

Topics: Interest Rates CUFT Intercompany Financing

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Intercompany Financing: Engie State Aid Case and Perrigo’s Battle with the IRS
May 31, 2021 by Harold McClure

Harold McClure explores intercompany financing issues through the lens of a recent case before the EU General Court and an upcoming battle between Perrigo and the IRS.

Topics: Interest Rates Europe United States Intercompany Financing

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Challenges to Intercompany Loan Rates by French Tax Authority and IRS
May 07, 2021 by Harold McClure

International tax law firms are rightfully warning clients of audit risks with respect to intercompany financing in France. Taxpayers can mitigate risk by following new OECD guidance, providing sound economic analysis and avoiding overly aggressive positions on group vs. standalone credit ratings.

Topics: Interest Rates United States France Intercompany Financing

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