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 & shared bottom lb ros

More from across our site

Direct Tax

US multinationals can’t sidestep pillar two: RSM tax leader

A global tax framework may not materialise anytime soon, but a common set of principles is becoming increasingly necessary, Rudolf Winkenius also tells ITR

Tom Baker, April 02 2025

Indirect Tax

Part of Eton College viewed from playing fields

UK court case on private school VAT policy begins

Kingsley Napley’s claimants are arguing that taxing the provision of education breaches the European Convention on Human Rights

Sam Sholli, April 01 2025

Direct Tax

Has Trump killed all hope of an effective pillar two?

While pillar two can progress without the US, it won’t reach the same heights without American involvement, argues Renáta Bláhová, founding partner of BMB Partners Taxand

Renáta Bláhová, March 31 2025

Direct Tax

Aerial view of Christ and Botafogo Bay from high angle.

Brazil’s proposed 10% withholding tax prompts local concern

There are unanswered questions as to how foreign investors could reclaim money via tax credits, advisers suggested

Sam Sholli, March 31 2025

Direct Tax

State of the market: analysing India’s ‘standout’ tax advisers

Amid an ever-changing tax environment, India’s advisory market is bustling with competition ahead of the 2025 World Tax rankings and ITR Awards

Ed Conlon, March 28 2025

Direct Tax

Oslo, Norway - 24 September 2022: PricewaterhouseCoopers or PWC

This week in tax: PwC reportedly reaches multimillion-dollar settlement with ex-partner over payouts

The deal comes after PwC had accused Paul McNab of using confidential information; in other news, McDermott hired a new London tax head from a US rival

Sam Sholli, March 28 2025

Transfer Pricing

UN TP subcommittee recommends intangibles analysis: report

Looking at transfer pricing simplification is “obviously helpful”, but it should be done in line with current standards, a senior government figure reportedly said

Sam Sholli, March 27 2025

Direct Tax

‘Is anything really changing?’ Experts react to UK Spring Statement

The UK Government’s plans to close the tax gap via increased HM Revenue and Customs investment have failed to impress local tax advisers

Sam Sholli, March 26 2025

Direct Tax

Hands of project managers discussing project management strategy

Who wins in the new battleground for contracted out R&D?

Under the merged scheme for R&D tax relief introduced last year, rules on contracted out R&D have changed. James Dudbridge argues for a proactive approach when reviewing companies’ commercial arrangements

James Dudbridge, March 26 2025

Copy of What Corporates Want 2025 (7).png

What Corporates Want: Southeast Asian advisers rock bottom on budgeting

Cultural nuances could account for tax advisers’ perceived poor cost management, a local partner told ITR

Tom Baker, March 25 2025