Local tax authorities have been successful in the past years in making reassessments of the intragroup financing and guaranties of multinational enterprises (MNEs). This is an area of improvement for MNEs and an area that can be easily audited and reassessed by the Tax Authorities.
Webinar -Transfer pricing aspects of intragroup loans and guaranties
- Date: March 25,2021
- Time: 2pm - 3pm CET
Click here to register
When the MNEs set their transfer pricing policy for their financial transactions, they should review :
- The OECD transfer pricing guidance on financial transactions;
- The Local Court Cases;
- The formal positions were taken by some Tax Authorities.
The transfer pricing documentation of MNEs should take into consideration the borrower’s credit rating as well as the main characteristics of the intragroup loan agreements (maturity, ranking subordination, currency, etc). Intragroup guarantees should also be documented.
On the agenda:
- Intragroup financing
- Intragroup guaranties
- The impact of the suppression of the LIBOR
- Court cases and local Tax Authorities’ positions
The panelists are:
- Ben Semper
- Nadja Horn
- Leopold Michaud
- Frédéric Lubczinski
- Akos Tomor
- Frédéric Barat