For transfer pricing purposes, a loan transaction must be considered from the lender`s and borrower`s perspective. Most of the time, a borrower`s perspective gets more attention, so it`s hard to miss something on that side. From the lender`s point of view, it is always important to consider alternative instruments to allow a lender to invest. An independent lender may have chosen not to invest the funds to create a safety cushion. In addition, it is possible to argue that an independent lender will apply for a guarantee for a loan and would not otherwise be willing to give funds at a much higher interest rate. It should also be noted that for existing loans (signed before 2020), an independent lender would re-evaluate existing loans to determine the impact of COVID-19 on the borrower`s creditworthiness. The secure port is available to Australian companies that have taken out an intercompany loan with the following main features: The best way to deal with these risks is to establish a timely transfer pricing report, which determines the length of an appropriate arm. In this context, it is important to understand how a group is financed and how it interacts with transfer pricing rules. This will allow companies to develop strong transfer pricing policies for financing agreements and to become comfortable with supporting documentation. In this article, we identify the usual types of funding and the different factors and approaches that should be taken into account in the treatment of these agreements. An independent lender will review the borrower`s circumstances prior to financing, and then free up resources for an agreed period under the loan terms, which may be a short-term facility or a multi-year agreement. As a result, the decisive moment for the valuation of a loan in accordance with transfer pricing rules is often the beginning of financing, based on forecasts and other information that would have been available at that time. Regardless of how a credit balance is established, transfer pricing considerations are generally defined by the following questions: the cross-border credit balance is calculated by aggregating all interest-rate and interest-free loans borrowed and borrowed by the Australian Economic Group.
Is the documentation on transfer pricing of intercompany loans the same as for other transactions? The interpretation of the application of the length principle for funding agreements continues to apply to many general aspects of these guidelines, such as the need to consider various facts and comparability factors in the analysis of how independent parties would have acted.