This content is from: United States
The implications of the credit crunch for intercompany loans
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
To access our market-driven intelligence please request a trial here.
Read this article – and more – for a 30 day period.
REQUEST ACCESSAre you already an ITR subscriber? Log in here