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.
US Tax Court favors unspecified method to determine royalty rate
The first US transfer pricing court decision of 2022 was published on Thursday, August 18, 2022, specifically Medtronic, Inc. and Consolidated Subsidiaries v....