The GE Capital case shone a spotlight on whether and how “implicit support” should be allowed for in the analysis of intra-group debt. This article explores implicit support in greater detail and begins to outline a transfer pricing framework for dealing with this issue.
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...