Transfer pricing adjustments on bank guarantees and loan support services are legally unsustainable without proper FAR analysis.
Transfer pricing adjustments on bank guarantees and loan support services are legally unsustainable without proper FAR analysis. Issue Whether transfer pricing adjustments made on counter/back-to-back guarantees (without establishing FAR comparability or data confrontation) and the arbitrary attribution of 50 percent net interest/fee income for loan support services (without a prescribed method or comparables) are sustainable?… Read More »