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This paper’s discussion begins by noting the credit spreads on long-term AAA and BBB government debt over the 1994 to 2008 period. The discussion next considers how the tax director for a hypothetical U.S. subsidiary that had incurred an intercompany loan two years ago might have successfully managed transfer pricing exposure by the use of the safe haven provision. The paper concludes by considering a situation where this U.S. subsidiary wishes to raise funds in today’s market through the use of an additional intercompany loan.
Mu hah ha aha. Blogs are evolving. You're looking at my Lifestream, a real-time flow of my activity across various websites, with the occasional blog post for nourishment.