The implications of the credit crunch for intercompany loans

February 24, 2009

Reliance on on the applicable federal rate (AFR) safe haven of section 1-482.2 of the Internal Revenue Code is not likely to address the need to comply with both US transfer pricing regulations and the expectation of the foreign tax authority that the interest rate on the intercompany loan be consistent with market interest rates for comparable loans

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & bottom lb ros

More from across our site

Direct Tax

Australian police search PwC Sydney office amid tax leaks scandal

Police may be inside the Sydney office for ‘several days’, PwC Australia’s chief executive officer said

Sam Sholli, November 04, 2024

Direct Tax

MELBOURNE, AUSTRALIA - JULY 30, 2018: PwC headquarters building in Melbourne Victoria Australia

PwC UK unmasked as source of A$1.2 million Burrowes payment

The source of additional remuneration received by PwC Australia CEO Kevin Burrowes had been the subject of much parliamentary scrutiny

Tom Ravlic, November 04, 2024

Indirect Tax

Part of Eton College viewed from playing fields

Kingsley Napley enlisted for private school VAT legal challenge

The Independent Schools Council is bringing litigation against the UK government for what it calls an ‘unprecedented education tax’

Tom Baker, November 01, 2024

Direct Tax

Oslo, Norway - 24 September 2022: PricewaterhouseCoopers or PWC

This week in tax: Pillar two underpins 6.3% PwC tax revenue growth

But the firm said that ‘difficult market conditions’ led to a slowdown in Asia Pacific; in other news, OECD begins Thailand accession process

Sam Sholli, November 01, 2024

Transfer Pricing

India retains TP tolerance ranges for 2024/25

The move will provide certainty to taxpayers and reduce the risk associated with pricing transactions for TP, according to India’s Ministry of Finance

Sam Sholli, October 31, 2024

Transfer Pricing

‘No reason to fiercely compete’: Aibidia on tax firm collabs

Pia Honkala, co-head of Aibidia’s operational TP product, tells ITR how her company works in harmony with advisers like the ‘big four’ to revolutionise clients’ processes

Tom Baker, October 31, 2024

Direct Tax

‘Our clients will be disappointed’: Experts criticise UK chancellor’s Budget

The UK is ‘heading to Scandinavia’ as its tax burden increases and isn’t creating an attractive environment for a wave of investment, experts have told ITR

Sam Sholli, October 30, 2024

Direct Tax

r and d - acronym from wooden blocks with letters. background hands on a laptop with blur. business concept.

UK R&D tax budget growth outpaced by OECD counterparts: report

Japan, South Korea and Germany increased their R&D tax budgets at a much greater rate over a 14-year period, say RCK Partners and the London Business School

Tom Baker, October 29, 2024

Direct Tax