CRA was engaged by a mid-market global investment company to conduct a loan interest rate benchmarking analysis. The analysis involved the determination of a synthetic credit rating of the borrower, and corresponding comparable bond yield analysis to benchmark the appropriate arm’s length interest rate. CRA also prepared the supporting OECD Master File and Local File compliant documentation.
Highlights from 2025 and looking forward to 2026
In the United States, 2025 brought major activity in high profile transfer pricing disputes and reaffirmed how closely transfer pricing, tariffs, and customs...