Skip to main content

NERA Special Consultant Dr. Alexander Voegele explores a number of transfer pricing issues affecting financial instruments in the latest edition of BNA International’s Transfer Pricing Forum. Dr. Voegele begins by examining whether the interest rates that are charged to related parties should be based on the stand-alone creditworthiness of each member of a multinational group. He also discusses whether related parties should be charged guarantee fees and how these fees should be calculated. The article concludes with a discussion on how to determine interest rates of cash pool debt and credit balances and how transfer pricing rules interact with thin capitalization rules.