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

Conference Schaffner 2000.png
ITR Indirect Tax Forum 2023: Govts turning companies into ‘free’ VAT auditors
The forum heard that VAT professionals are struggling under new pressures to validate transactions and catch fraud, responsibilities that they say should lie with governments.
Euan Healy, May 26, 2023
AdobeStock_494001486_Editorial_Use_Only (1).jpg
OECD paper raises potential carbon tax improvements
The working paper suggested a new framework for boosting effective carbon rates and reducing the inconsistency of climate policy.
Euan Healy, May 26, 2023
jonathan-kemper-chatgpt.jpg
This week in tax: TaxGPT becomes 'first' AI-powered tax assistant
UAE firm Virtuzone launches ‘TaxGPT’, claiming it is the first AI-powered tax tool, while the Australian police faces claims of a conflict of interest over its PwC audit contract.
Josh White, May 26, 2023
mohamed-m-apple.jpg
Analysis: EU Commission’s last chance to beat Apple
The US technology company is defending its past Irish tax arrangements at the CJEU in a final showdown that could have major political repercussions.
Josh White, May 25, 2023
Data currency 2000.jpg
ITR Indirect Tax Forum 2023: Meta VAT investigation could 'blow up'
ITR’s Indirect Tax Forum heard that Italy’s VAT investigation into Meta has the potential to set new and expensive tax principles that would likely be adopted around the world
Euan Healy, May 24, 2023
MELBOURNE, AUSTRALIA - JULY 30, 2018: PwC headquarters building
Former PwC Australia partner faces criminal investigation over tax leaks
Police are now investigating the leak of confidential tax information by a former PwC partner at the request of the Australian government.
Courtney Wilson, May 24, 2023
ViDA EU 2000.png
ITR Indirect Tax Forum 2023: Convergence deadline for ViDA reporting in doubt
A VAT policy officer at the European Commission told the forum that the initial deadline set for EU convergence of domestic digital VAT reporting is likely to be extended.
Euan Healy, May 23, 2023
Big Ben and Houses of Parliament, London, UK
UK corporate tax hike hits mid-sized business investment
The UK government shows little sign of cutting corporate tax, while a growing number of businesses report a decline in investment as a result of the higher tax burden.
Courtney Wilson, May 23, 2023
Local Insights
business-5082991.jpg
Portuguese tax incentive to the capitalisation of companies
Mariana Morais Teixeira of Morais Leitão overviews Portugal’s new tax incentive regime designed to boost the country’s capital-depleted private sector.
Mariana Morais Teixeira, May 23, 2023
adrian-pranata-jakarta.jpg
Indonesia’s hopes for pillar one
Septian Fachrizal, TP analyst at the Directorate General of Taxes, outlines how Indonesia is relying heavily on the successful implementation of pillar one.
Septian Fachrizal, May 22, 2023