The implications of the credit crunch for intercompany loans

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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

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