- Matters which can be applied to all international related party dealings, such as:
- The relevant commercial and economic evidence required to support related party dealings as arm's length.
- Practical considerations when amending related party agreements.
- Matters specific to international related party funding arrangements, such as:
- The relevance of credit rating agencies and debt capital market practices.
- The impact of group policy and practice when assessing the potential for parental guarantees and the charging of guarantee fees.
- This presentation also considers the positions of the parties on appeal, and what wider implications the appeal may have for transfer pricing practices and practitioners.
maintenance