The Resource Financial transactions question

Financial transactions question

Financial transactions question
Financial transactions question
QUESTIONS: By reference to national legislation, guidance, case law and practice, what is the position in your jurisdiction on the following financial transactions transfer pricing issues: I. Issue One: Should the interest rate to be charged to related parties reflect their stand-alone creditworthiness? II. Issue Two: Should stand-alone creditworthiness be adjusted upwards to reflect the possibility of parental or wider group financial support? III. Issue Three: Should related parties be charged guarantee fees? IV. Issue Four: How should related party guarantee fees be calculated? Should they be adjusted downwards to reflect the possibility of parental or group support? V. Issue Five: In cases where debt is raised from external sources but with the benefit of a related party guarantee, how is that guarantee taken into account in assessing the deductibility of interest (and other incidental costs of borrowing) by the borrower? VI. Issue Six: How should the interest rates on cash pool debit and credit balances be determined? VII. Issue Seven: How do the transfer pricing rules interact with any thin capitalisation rules?
Citation source
In: Transfer pricing forum. - Arlington. - Vol. 1 (2010), no. 4 (October) ; 79 p
Geographic coverage
Language note
  • financing
  • transfer pricing
  • interest
  • debt
  • associated enterprises
  • cash pooling
Financial transactions question

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...