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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Building a transparent culture, prioritising internal promotions and being different from the big four are all key features of A&M Tax’s ambitious plans for India
But businesses should remain flexible when choosing between internal and external resources to handle added ViDA complexity, ITR’s Indirect Tax forum also heard