Searching for Implicit Support Transfer Pricing information? Find all needed info by using official links provided below.
https://www.crai.com/sites/default/files/publications/Dealing-with-implicit-support-in-relation-to%20intra-group-debt.pdf
In summary, the Court determined that implicit support from a parent company was an economic factor that needed to be taken into account in an arm’s length transfer pricing analysis and that the value implicit support provided to the subsidiary should not be charged for.
https://tpcases.com/tag/implicit-support/
Implicit support refers to the fact that the credit rating of a company that is part of a MNE group may be higher (and interest rate therefor lower) than it would be if it was a stand-alone company, if a bank or rating agency believes that associated enterprises would support the company in a period of financial stress even in the absence of an explicit guarantee.
https://www2.deloitte.com/content/dam/Deloitte/us/Documents/Tax/us-tax-beps-changes-transfer-pricing-passive%20association.pdf
Transfer Pricing Guidelines will need to consider whether this issue is relevant. In pricing funding transactions, it may be necessary to consider whether the credit markets would have actually considered the impact of implicit or nonbinding credit support. It may be, of course, that local transfer pricing law in any given jurisdiction follows a
https://tpguidelines.com/tag/implicit-support/
Implicit support refers to the fact that the credit rating of a company that is part of a MNE group may be higher (and interest rate therefor lower) than it would be if it was a stand-alone company, if a bank or rating agency believes that associated enterprises would support the company in a period of financial stress even in the absence of an explicit guarantee.
https://news.bloombergtax.com/transfer-pricing/insight-2020-transfer-pricing-controversy-forecast-what-who-and-how
Recent transfer pricing developments will likely cause controversy in 2020. Clive Jie-A-Joen, Monique van Herksen, and Fan Bai of SImmons & Simmons in this transfer pricing Outlook examine who is likely to be targeted and how best to tackle the issues.
https://tp.taxsutra.com/experts/column?sid=371
Jun 20, 2017 · Noting that the OECD guidance provides that there is no fee or payment required for implicit support, the authors opine that “while considering a hypothetical transaction or benchmarking data, implicit support cannot be ignored”. ... While transfer pricing is not an exact science, in most cases, credit rating agencies follow a standard ...
https://www2.deloitte.com/global/en/pages/tax/articles/transfer-pricing-beps-base-erosion-and-profit-shifting-practical-guide.html
The new transfer pricing landscape ... This article provides some context to the issue of “passive association” and implicit credit support that may be provided within multinational groups. It includes an explanation of the OECD’s new position on this issue, why it matters, and the practical consequences for multinationals, specifically ...
https://www.ey.com/gl/en/services/tax/international-tax/alert--oecd-releases-first-discussion-draft-on-transfer-pricing-aspects-of-financial-transactions
Jul 06, 2018 · More difficult transfer pricing issues may arise, however, if the contract instrument is entered into by the treasury company or another group company, with the result that the positions are not matched within the same company, although the group position is protected. ... it is important to take into account the impact of implicit support on ...
http://newsletters.usdbriefs.com/2014/Tax/ALS/140921_2.pdf
OECD Chapter I Release: Important Guidance on Location-Specific Advantages and Passive Association The OECD’s revised guidance in Chapter VI of the transfer pricing guidelines defines intangibles as assets other than physical or financial assets that are capable of being owned or controlled by a single enterprise. Under this definition, location-
https://www.pwc.com/gx/en/tax/transfer-pricing/assets/full-report-2013.pdf
association/implicit support in substantiating the arm’s length nature of interest rates/guarantee fees. Given the inconsistency in global transfer pricing rules, planning and management of intercompany financial transactions from a transfer pricing perspective is challenging.
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