A robust and compliant approach to estimate the arm's length rate of an intragroup financing instrument
TP qube has streamlined the full process to estimate the arm’s length rate of intragroup loans, allowing us to be more accurate and consistent in the estimation of the credit rating of the borrower and subsequently of the interest rate. We strive to provide these analyses faster and cheaper for our clients.
We partnered with a global leading financial information platform to provide fully independent and objective interest rate analyses.
All our analyses are performed by experienced TP staff, ensuring the final quality of the deliverables.
A four-step process
Data gathering (incl. phone call and information request)
Credit rating estimation (optional)
Get fast and accurate results, able to convince tax authorities
We follow a straightforward process allowing us and our clients to waste no time.
Our analyses are tailored to the characteristics of the facility and the tested parties (industry, geography, maturity, seniority, creditworthiness, etc.), and respect guidelines and recommendations of international institutions (OECD, UN) as well as local tax authorities.
We guarantee on-time delivery in pre-agreed timeframe.
Q&A
We cover all industries and the main geographies (Australia, Austria, Belgium, Brazil, Canada, China, Denmark, Finland, France, Germany, Hong Kong, India, Indonesia, Israel, Italy, Japan, Korea (Republic of), Malaysia, Mexico, Netherlands, New Zealand, Norway, Philippines, Portugal, Russian Federation, Singapore, Spain, Sweden, Switzerland, Taiwan, United Kingdom, United States of America).
No. The need of credit rating depends on the specifics of the case at hand. In some situations (such as an important implicit support of the parent), the credit rating of the group can be relied upon to derive the interest rate, and no additional work is needed.
Quite a lot! We take into account the characteristics of the intragroup financing instrument such as the industry and geography of the borrower, its creditworthiness, the currency, maturity, seniority of the financing instrument, etc.
No. Assessing the arm’s length nature of a cash pool system relies on a different approach.
It notably focuses on the functional analysis of the head of the cash pooling. Also, in some cases, parts of the cash pooling may be requalified as long term loans.
Please contact us at info@tpqube.com if you need more information.
Financial guarantee should, in general, also be priced. The approach shares features with the one used to price arm’s length interest rates.
Please contact us at info@tpqube.com if you need more information.
All analyses are performed in France by our experienced transfer pricing experts.
Do not hesitate to contact us: info@tpqube.com. It will be our pleasure to help you.