The Determination and Assessment of the Appropriateness of Interest Rates in the Case of Cross-Border Financial Transactions between Related Parties – A Case Study

Journal
International
International Transfer Pricing Journal 2020 (Volume 27), No. 1
Assessing the appropriateness of interest rates for loan relationships in multinational groups or corporate groups may be the subject of controversial discussions in tax audits. On the basis of a two-stage concept, the case study is intended to provide the practical determination of the interest rates for such transactions. This gradually developed case study serves as a fruitful instruction for consulting practice, administration and jurisdiction, while realizing an appropriate arms’ length interest rate.