The implications of the credit crunch for intercompany loans

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

The implications of the credit crunch for intercompany loans

February 24 2009

Reliance on on the applicable federal rate (AFR) safe haven of section 1-482.2 of the Internal Revenue Code is not likely to address the need to comply with both US transfer pricing regulations and the expectation of the foreign tax authority that the interest rate on the intercompany loan be consistent with market interest rates for comparable loans

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

NewsUnited StatesTransfer PricingNorth America Jurisdictions
more across site & shared bottom lb ros

More from across our site

Indirect Tax
nitin argawal resized.jpg
ITR Award Winner Series: Nitin Agarwal, Majid Al Futtaim
Corporate counsel should combine deep technical knowledge with strategic dynamism, says Agarwal, winner of ITR’s EMEA In-house Indirect Tax Leader of the Year award
October 08 2025
Direct Tax
Luxembourg tax
Luxembourg’s tax policy 2025: delivering the coalition’s mandate for competitiveness
Luxembourg’s reform agenda continues at pace in 2025, with targeted measures for start-ups and alternative investment funds
Jean-Dominique Morelli , October 07 2025
Direct Tax
Stuttgart, Germany - 06-19-2022: Cellphone with logo of American consulting company Alvarez and Marsal LLC on screen in front of website. Focus on center-right of phone display.
A&M Tax hires five ex-EY partners for new corporate practice
Veteran Elizabeth Arrendale will lead the new advisory practice, which will support clients with M&A tax structuring, post-deal integration, and more
Tom Baker, October 06 2025
Direct Tax
WhatsApp Image 2025-10-02 at 09.39.44 (1).jpeg
OECD victim of own success with MAPs: tax certainty co-head
MAP cases keep increasing, and cases closed aren’t keeping pace with the number started, the OECD’s Sriram Govind also told an ITR summit
Sam Sholli, October 06 2025
Direct Tax
ITR awards EMEA 2025
A taxing week: In defence of directories
Nobody likes paperwork or paying money, but the assertion that legal accreditation doesn’t offer value to firms and clients alike is false
Tom Baker, October 03 2025
Direct Tax
handshake
This week in tax: US tax firm Ryan acquires stake in India’s Dhruva Advisors
Ryan hopes the buyout will help it expand into Asia and the Middle East; in other news, three German finance ministers have called for a suspension of pillar two
Sam Sholli, October 03 2025
Direct Tax
High court 2000.jpg
Danish tax authority loses £1.4bn UK fraud case
SKAT, which was represented by Pinsent Masons, had accused Sanjay Shah and other defendants of fraudulent dividend tax refund claims
Tom Baker, October 02 2025
Transfer Pricing
TP Europe 2025 business restructuring panel
TP success requires tight internal relations, in-house experts say
TP managers must be able to explain technical issues in simple terms, ITR’s European Transfer Pricing Forum heard
Tom Baker, October 02 2025
Indirect Tax
uksc-court-sittings-2023.jpg
This month in indirect tax: Baker McKenzie client fails in UK Supreme Court VAT appeal
Prudential had challenged HMRC over VAT group relief; in other news, Donald Trump unveiled timber and wood tariffs, and the European Commission published a ViDA implementation strategy
Sam Sholli, October 01 2025
Direct Tax
Washington DC Capitol view on cloudy sky background
US tax coalition petitions Treasury, defends Australian CbCR
Australia’s CbCR rules have ‘widespread support’ and do not put American companies at a competitive disadvantage, the FACT Coalition said
Tom Baker, September 30 2025
Gift this article