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.
While UN proposals to shift airline taxation from a residence-based system to a source-state one are not set in stone, ex-British Airways CEO Willie Walsh warns they would increase costs and complexity
Von Wobeser y Sierra’s head of tax shares best practices for resolving tax controversy and touts his firm’s founding partner as an exemplar of legal practice
Experts from law firm Kennedys outline the key tax disputes trends set to define 2026, ranging from increased enforcement to continued tariff drama and AI usage
They also warned against an ‘unnecessary duplication of efforts’ in UN tax convention negotiations; in other news, White & Case has hired Freshfields’ former French tax head
Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities