Did you know that your browser is out of date?
For the best experience we recommend upgrading to the latest version of these supported browsers:
I wish to continue viewing on my unsupported browser
Applying the Arm’s Length Principle to Intra Group Financial Transactions: A Reference Guide
31 August 2023
Amanda Pletz, Dr. Emmanuel Llinares, Dr. Niraja Srinivasan, Timothy McKenna, Ralph Meghames, Dr. Ronald Bernstein, Bernardo Danesi, Eugene Ng, Gary Lambert, and Mark Berenblut
A new transfer pricing book from Kluwer Law International, Applying the Arm’s Length Principle to Intra Group Financial Transactions: A Reference Guide, is now available for order. The book covers in-depth practical and policy-related issues in intra-group financial transactions. Co-edited by NERA Director Amanda Pletz, the book features contributions from more than 50 experts, including 10 from NERA, and shares practical case studies covering legal and economic aspects that contextualize the application of the arm’s length principle to intra-group financing transactions.
Given the challenges taxpayers and tax authorities are facing, this book will prove an immeasurably valuable reference guide for tax practitioners, tax administrations, and tax scholars in developing standards and policies dealing with intra-group financing issues.
- NERA Director Ralph Meghames, Ms. Pletz, and Consultant Bernardo Danesi co-wrote the chapter “Fixed Rate Loan Transactions: A Case Study,” which analyzes the analytical framework pertaining to benchmarking fixed-rate loan transactions.
- Head of Global Transfer Pricing Dr. Emmanuel Llinares and Mr. Danesi wrote “Assessing Factoring Transactions Within the Arm’s Length Principle.” The chapter explains the complexity of characterizing and benchmarking factoring transactions and provides an account of the considerations a transfer pricing practitioner should make in relation to factoring transactions.
- Dr. Llinares and Mr. Danesi also wrote “Pricing Factoring Transactions: A Case Study,” which uses a factoring arrangement example to engage with typical considerations that should be made when pricing an arrangement in conformity with the arm’s length principle.
- Ms. Pletz and Affiliated Consultant Mark Berenblut’s chapter “Transfer Pricing Considerations for Intercompany Cryptocurrency” provides an overview of factors affecting the financial dynamics and associated risks of crypto funding and their considerations for transfer pricing.
- Director Timothy McKenna wrote “The Use of CDSs When Pricing Debt Guarantees.” The chapter discusses the use of credit default swaps to access a standardized data set of credit risk measures.
- Former Managing Director Dr. Niraja Srinivasan co-wrote the chapter “Hedging Options in Multinationals,” in which she discusses the financial risks of multinational enterprises and how hedges operate to offset these risks.
- Ms. Pletz, Economic Analyst Eugene Ng, and Affiliated Consultant Gary Lambert provide practical examples of how other methods can be used for loan benchmarking when comparable transactions are not available in their chapter “The Use of Other Methods for Loan Benchmarking: A Yield Build-Up Approach and Cost of Funds.”
- Mr. Lambert also wrote “Using the Actuarial Approach to Price Guarantees,” which describes the methodology of the actuarial approach and how it assesses the losses a guarantor will have to face in the context of a binding guarantee agreement.
- Ms. Pletz co-drafted two chapters on captive insurance: “Setting the ALP Framework for Captive Insurance” and “Accurate Delineation of Captive Insurance Transactions Including Options Realistically Available.” These chapters set out the key factors that should be considered when analyzing and applying the arm’s length principle to captive insurance transactions.
- Ms. Pletz and Principal Dr. Ronald Bernstein co-drafted “The Issue of Implicit Support and Implications for a Transfer Pricing Analysis.” The chapter provides a high-level reflection on how to consider implicit support based on available information from the rating agencies and financial market participants.
Order Applying the Arm’s Length Principle to Intra Group Financial Transactions: A Reference Guide from Wolters Kluwer here.
Applying the Arm's Length Principle to Intra Group Financial Transactions: A Reference Guide
SKU:10092604-0001
Robert Danon, Vikram Chand, G. Maisto, Amanda Pletz