As countries continue implementing the guidelines from the OECD’s BEPS action plan, corporations are facing increasing challenges in conducting transparent intercompany loan transfer pricing transactions.
In this webinar we discuss:
- Arms-Length Principle Interest Rate Approaches
- Probability of Default, Expected Loss and Rating Calculations
- Case Study: Holding Challenges
- Applying Credit Models for Thin Capitalization Analysis and Guarantee Fees Methodologies
This article is intended as guidance for transfer pricing professionals in Luxembourg who are considering the equity-at-risk following the calculation of a loan's expected loss when using Moody's Analytics tools. This article does not provide final decision-making processes, which remain at the discretion of the transfer pricing professional, according to the specific case. This article is intended to create elements of thought and paths to economically and financially sound results.
November 2018 Pdf Christophe Marinier