International Tax Review is part of the Delinian Group, Delinian Limited, 8 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2023

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

The implications of the credit crunch for intercompany loans

February 24, 2009
Share

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 article.

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

To unlock this article:

Take a Free Trial or Login

Tags

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

More from across our site

germany berlin reichstag building german parliament bundestag - Concept piece for power, authority, economy, performance, government, planning and control.
This week in tax: Germany publishes corporate minimum tax plan
The German government unveils plans to implement pillar two, while EY is reportedly still divided over ‘Project Everest’.
Josh White, March 24, 2023
Sponsored
planning-3536758.jpg
Building value – ITR’s M&A Guide 2023 launched
With the M&A market booming, ITR has partnered with correspondents from firms around the globe to provide a guide to the deal structures being employed and tax authorities' responses.
Phil Myers, March 23, 2023
Shanghai is the financial centre of China
UFLPA’s influence on MNEs’ TP comparability analysis in China
Xing Hu, partner at Hui Ye Law Firm in Shanghai, looks at the implications of the US Uyghur Forced Labor Protection Act for TP comparability analysis of China.
Xing Hu, March 23, 2023
Karl Berlin_Ørsted_ITR.jpg
Q&A: Ørsted’s head of tax on the risks to renewables
Karl Berlin talks to Josh White about meeting the Fair Tax standard, the changing burden of country-by-country reporting, and how windfall taxes may hit renewable energy.
Josh White, March 23, 2023
Cancellations driven by COVID-19 are hurting businesses
The tax challenges of global mobility
Sandy Markwick, head of the Tax Director Network (TDN) at Winmark, looks at the challenges of global mobility for tax management.
Sandy Markwick, March 22, 2023
NZ backdrop.jpeg
Why New Zealand’s TP simplification measures are anything but
Taxpayers should look beyond the headline criteria of the simplification regime to ensure that their arrangements meet the arm’s-length standard, say Alejandro Ces and Mark Seddon of the EY New Zealand transfer pricing team.
Alejandro Ces, March 22, 2023
IRS AND ATO.png
IRS and ATO aim to expand and modernise, say senior officials
In a recent webinar hosted by law firms Greenberg Traurig and Clayton Utz, officials at the IRS and ATO outlined their visions for 2023.
Courtney Wilson, March 21, 2023
Women in Business Law Awards APAC 2023 Logo
Women in Business Law Awards APAC 2023: open for submissions
The Asia-Pacific awards research cycle has now begun – don’t miss on this opportunity be recognised in 2023
John Harrison, March 21, 2023
UN_logo_2000x.jpeg
Why 2023 may determine the future of international tax policy
An intense period of lobbying and persuasion is under way as the UN secretary-general’s report on the future of international tax cooperation begins to take shape. Ralph Cunningham reports.
Ralph Cunningham, March 20, 2023
Gavel of judge with coins against European Union flag
This week in tax: Amazon hearing and Amgen lawsuit
Fresh details of the European Commission’s state aid case against Amazon emerge, while a pension fund is suing Amgen over its tax dispute with the Internal Revenue Service.
Josh White, March 17, 2023