Transcription of Important Considerations in the Pricing of …
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Www .willamette .com INSIGHTS WINTER 2015 19 Important Considerations in the Pricing of Intercompany Loans and Financial GuaranteesMatt C. CourtnageIntercompany Transfer Price InsightsOver the past several years, taxing authorities have devoted increasing attention to intercompany loans and financial guarantees in terms of their tax treatment and Pricing Considerations . This attention is especially evident in the international arena, where cross-border financial transactions involving loan rates and guarantee fees can lead to profit erosion. For these intercompany financial transactions, there is a great deal of complexity for both the taxpayer and the national taxing authority in determining a reasonable arm s length transfer price.
www .willamette .com INSIGHTS • WINTER 2015 19 Important Considerations in the Pricing . of Intercompany Loans and Financial Guarantees. Matt C. Courtnage
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The Controlled Foreign Companies Excluded, The Controlled Foreign Companies (Excluded Territories) Regulations, Going Global- 5 Risk Management Issues, Controlled, Companies, International Traffic in Arms Regulations, FATCA, Foreign, International Taxation – Overview of Key Concepts, Explanation of Combined Reporting