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

Unlock this content.

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

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

Beyond the headlines: Lessons from pillar two’s first and farcical filing deadline

ITR spoke to multinationals, advisers and software providers about a June 30 deadline defined by faulty portals, high compliance costs and hard lessons

Tom Baker, July 20 2026

Direct Tax

Compliance frustration onerous pillar two

A taxing week: Pillar two revenue shortfall a gut-punch for MNEs

After years of onerous pillar two prep, businesses will be galled in seeing tax revenues outweighed by compliance costs

Tom Baker, July 17 2026

Direct Tax

The EY US dispute: why secondment structures need fresh Indian review

Tax advisers should revisit India secondment arrangements after the EY US ruling strengthened the Centrica precedent and raised fresh withholding concerns

Aditi Goyal, July 16 2026

Direct Tax

Pillar two revenues lower than anticipated, OECD admits

Despite the shortfall, effective tax rates of multinationals have seen a ‘statistically significant rise’

Sam Sholli, July 15 2026

Direct Tax

Behind the hire: Stuart Alter on developing Milbank’s fund formation practice

After joining Milbank from Akin Gump, the fund tax specialist discusses sponsor demand, practice building, and the tax challenges facing asset managers

Tom Baker, July 15 2026

Direct Tax

KPMG Australia set to axe hundreds of jobs amid scandal: AFR

Partner payouts could also be reduced by a fifth, it has been reported

Sam Sholli, July 14 2026

Direct Tax

US trade body criticises ‘inconsistent’ EU pillar two exemption

There is no logical reason not to extend an exemption from EU CFC rules to multinationals headquartered in side-by-side jurisdictions, USCIB said

Sam Sholli, July 14 2026

Direct Tax

Beyond the headlines: Why tax is moving up the merger agenda

While rarely the sole driver of a combination, tax is becoming an increasingly important part of firms' efforts to keep up with client expectations

Sam Sholli, July 13 2026

Transfer Pricing

A taxing week: Why delegating document work to LLMs is riskier than you think

New research, which suggests LLMs can silently corrupt complex documents, should alert tax and legal teams relying on AI to handle iterative drafting and compliance workflows

Marc Mokrab, July 10 2026

Direct Tax

PM-in-waiting Burnham unlikely to deviate from tax agent registration: experts

Maintaining increased funding for HMRC is a ‘high possibility’ if he becomes PM, ITR has also heard

Sam Sholli, July 09 2026