Financial Sector Tax Litigation

The Situation

Several clients retained NERA experts to provide economic support in tax litigation related to valuation of corporate guarantees provided as part of complex cross-border financing structures.

NERA's Role

NERA experts prepared detailed reviews of the transactions and the related parties involved, and performed analyses of credit ratings and net risk exposures of the parties. Due to complexity of the transactions, the valuation methodologies and parameters varied from one case to another.

The Result

NERA prepared robust and defendable estimates of arm's length remuneration of guarantees provided by parent organizations to special purpose subsidiary vehicles.