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International - Is a Letter of Comfort a Chargeable Intra-Group Service?

Country:
International
Author:
S.K. Bilaney
Issue:
International Transfer Pricing Journal, 2017 (Volume 24), No 3
Published:
6 April 2017
The author considers the situation where a parent or regional holding company issues a letter of comfort to a bank or financial institution that lends money to the borrowing subsidiary. The differences between a letter of comfort and an explicit guarantee are discussed, along with the attendant transfer pricing implications.
 
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