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The determination and assessment of the appropriateness of interest rates in the case of cross-border financial transactions between related parties Stefan Greil and Dirk Schilling Electrónico

By: Greil, Stefan.
Contributor(s): Schilling, Dirk.
Material type: ArticleArticlePublisher: 2020Subject(s): GRUPOS DE EMPRESAS | CREDITO | INTERES | IMPUESTOS | PRECIOS DE TRANSFERENCIA | OPERACIONES TRANSFRONTERIZAS | AUDITORIA FISCAL In: International Transfer Pricing Journal v. 27, n. 1, January 2020, p. 28-35Summary: 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.
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Resumen.

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.

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