Can you provide details on the nature of any intercompany loans or financing arrangements?
Intercompany loans and financing arrangements typically include:
1. Loan Terms: Details such as interest rates, repayment schedules, and loan duration. These must reflect market conditions to ensure compliance with transfer pricing regulations.
2. Interest Rates: Set based on market benchmarks or reference rates (e.g., LIBOR), ensuring the rate is at arm's length.
3. Guarantees: Some loans involve parent companies or related entities acting as guarantors for lower borrowing costs.
4. Currency of Loan: Loans may be denominated in different currencies depending on the jurisdiction and financial strategy.
5. Purpose of Loan: Funds are often provided for working capital, capital expenditure, or expansion efforts.
These arrangements must adhere to Transfer Pricing & Safe Harbour Rules to ensure fair and compliant pricing across jurisdictions.
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