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.
ITR World Tax Guide 2025: Rebel Curd and David Kemp recognized
Congratulations to Rebel Curd and David Kemp for their recent recognition as “highly regarded” leaders in International Tax Review’s (ITR) 2025 World Tax...