Forecasting Interest Rates for Future Inter-Company Loan Planning: An Alternative Approach
AbstractInter-company loans do not draw considerable attention from Multinational Enterprises (MNEs) because they are not core business-related transactions, but planning an interest rate for them is actually important in countries with transfer pricing legislation. Nonetheless, Organisation for Economic Cooperation and Development (OECD) Guidelines do not point to concrete direction about methods or approaches to be performed in order to incorporate arm´s length principle in interest rates for future inter-company loans.Transfer pricing analysis for inter-company loans are usually performed applying the Comparable Uncontrolled Price Method (CUP method). The CUP method compares the interest rate of inter-company loans with statistical ranges built over interest rates of market comparable transactions. Interquartile Range (IQR) is a common statistical range to establish comparison. In accordance with the CUP method in transfer pricing analysis, Plunkett and Mimura mentioned corporate bonds markets are a rich source of data for identifying market interest rates and for which there is sufficient data to establish comparability" (Plunkett & Mimura, 2005).Aditionally, Plunkett and Powell suggest the use of data from corporate bond yields in accordance with credit rating of the borrower as supplementary (Plunkett & Powell, 2008)."
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Bibliographic InfoPaper provided by DEPARTAMENTO NACIONAL DE PLANEACIÓN in its series ARCHIVOS DE ECONOMÍA with number 005840.
Date of creation: 16 Sep 2009
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Transfer pricing; planning; interest rate; inter-company loan; interquartilerange;
Find related papers by JEL classification:
- F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
- K34 - Law and Economics - - Other Substantive Areas of Law - - - Tax Law
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- Jiří Jakoubek, 2012. "Limits to the Price Formation: Possibilities and Implications of Setting a Common Interest Rates," Český finanční a účetní časopis, University of Economics, Prague, vol. 2012(4), pages 102-119.
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