In this episode of Beyond the Ledger, host, Shardae Layfield, alongside the expertise of, Ben Miller and Abbas Raza discuss the complexities of financing transactions within the realm of transfer pricing. The guests discuss the importance of understanding inter-company debt versus payables, the necessity of proper documentation, and the common pitfalls companies face. They also explore how to establish arm’s length interest rates, the implications of global tax authority expectations, and the use of safe harbor rates. The discussion emphasizes the need for companies to be proactive in managing their financing transactions to avoid potential audits and recharacterization issues.

Takeaways

• Financing transactions are often overlooked in transfer pricing discussions.
• Documentation is crucial for defending inter-company loans during audits.
• Time can exacerbate small issues into significant problems in financing transactions.
• The IRS uses data analytics to identify potential issues in inter-company financing.
• Establishing arm’s length interest rates requires understanding both borrower and lender perspectives.
• Common operational missteps can lead to significant tax implications.
• Safe harbor rates provide a useful tool for pricing inter-company loans.
• Debt to equity misalignments can trigger audits and recharacterization risks.
• Narrating a coherent story is essential for defending transfer pricing strategies.
• Foreign tax authorities may accept U.S. safe harbor rates if they do not disadvantage their tax base.

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