Intra-group financing transactions are a way for corporate groups to promote efficient capital allocation, stimulate development and provide more flexibility and control over financial resources than external financing. However, as with all other intra-group business transactions, transfer pricing risks should not be forgotten in financing transactions.
This article discusses an important but sometimes overlooked comparability factor to consider in cross-border financing transactions with related parties: the sovereign risk premium.
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Ask questionGenerative artificial intelligence (GenAI) has become an essential business tool that helps companies optimise their processes, improve efficiencies and cut costs. However, to better understand GenAI’s impact on finances, it’s important to consider the cost of this tool from different aspects.
In everyday life, companies have to use an option such as borrowing money for various specific purposes. A significant increase in debt can present the company with challenges that impact balance sheet performance and potential tax risks.
One solution to the problem of increasing debt can be to capitalise the loan – a process whereby the creditor invests its debt rights as a financial asset in the borrower's equity.
This article describes the nature of the loan transaction and its capitalisation with practical examples of possible situations dealing with both corporate income tax (CIT) and transfer pricing (TP) aspects.
In today’s rapidly changing world, organisations need to be proactive to stay competitive and they also need to regularly assess potential business risks and opportunities. When it comes to assessing risks and opportunities, businesses often opt for enterprise risk management – the culture, capabilities and practices an organisation integrates with setting a strategy and applies when it carries out that strategy, with the purpose of managing risk in creating, preserving and realising value.
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