Category Adjustments

Financial Transactions, Adjustments, Arm's Length Interest Rates, Intercompany Financing, OECD, United Nations

Fixed-Rate Intercompany Loans and Currency Denomination

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.

Harold McClure
September 7, 2022

CUFT, Adjustments, Arm's Length Interest Rates, Intercompany Financing, State Transfer Pricing

Tutorial: Country Risk Adjustment in Intercompany Financing

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.

John Hollas
March 4, 2022

Fixed-Rate Intercompany Loans and Currency Denomination

Tutorial: Country Risk Adjustment in Intercompany Financing

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