International - Transfer Pricing and Intra-Group Financing: Low-Hanging Fruit?
- A.J. Bakker
- Derivatives & Financial Instruments, 2013 (Volume 15), No 2
- 19 February 2013
The author provides an overview of the transfer pricing issues related to intra-group financing. Topics considered include the reasons for increased controversy in this field, what taxpayers should bear in mind when intercompany loans are in place and a new loan agreement with related parties will be concluded, and the potential issues with guarantees and cash pooling. Some recommendations are also offered.