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
Greil, S.; Schilling, D.
International
International Transfer Pricing Journal 2020 (Volume 27), No. 1
PriceUSD 45

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.