Intercompany Loan Pricing Advisory
We determine appropriate interest rates for cross-border intercompany loans and prepare the required transfer pricing documentation.
Why Intercompany Loan Pricing Matters
When companies provide loans to related entities in another country, tax authorities expect the interest rate and terms to reflect the borrower’s credit profile, the specific loan conditions, and the commercial reality of the transaction
If the pricing does not properly reflect these factors, tax authorities may challenge the arrangement, adjust taxable income and impose penalties and interest.
Our Services
We provide specialist transfer pricing analysis for cross-border intercompany loans.
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A full transfer pricing analysis of a specific cross-border intercompany loan, including credit assessment, market benchmarking, and a written report suitable for tax compliance and audit support.
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Independent benchmarking of an intercompany loan to determine an arm’s length interest rate range based on comparable third-party market data.
This service is suitable where a credit analysis has already been performed or where documentation support is not required.
Our Process
1. We Review the Loan
Before setting the interest rate, we first review the loan itself.
We assess:
Why the loan was made
Whether the borrowing company could realistically obtain that amount of funding from a bank
Whether the loan amount is reasonable given the company’s financial position
Whether the terms (repayment schedule, maturity, security) reflect normal commercial practice
If a loan does not reflect commercial reality, tax authorities may question whether it should be treated as debt.
In that case, part or all of the interest may be denied as a tax deduction, which can increase taxable income.
This first step ensures the loan structure is commercially sound before we determine the interest rate.
2. We Assess the Borrower’s Financial Strength
The financial strength or creditworthiness of the borrowing company is an important factor in determining the correct interest rate.
A company that is financially stable can borrow at a lower rate.
A company with higher risk will typically pay a higher rate.
We review the borrower’s financial position to understand how a normal bank would assess the risk of lending to that company.
Where relevant, we also consider whether support from the wider group affects that assessment.
3. We Determine the Interest Rate
Once we understand the loan amount, the borrower’s financial strength, and the loan terms, we determine the appropriate interest rate.
We do this by reviewing comparable loans between independent companies in the market.
These comparisons help us identify a reasonable interest rate range based on real market data.
This ensures the rate reflects normal commercial conditions — not internal policy.
4. We Prepare Clear Documentation
We prepare a written report that explains:
The purpose and structure of the loan
The borrower’s financial assessment
The basis for the interest rate
The market data considered
The report sets out the reasoning behind the pricing in a clear and structured way.
This documentation can be used to support the company’s position in the event of a tax review or audit.
Who We Work With
We typically advise:
Small and mid-sized multinational groups with cross-border intercompany loans
Accounting and transfer pricing firms requiring specialist financial transactions expertise
Law firms advising on tax-sensitive financing and restructuring matters
Corporate tax departments seeking defensible and technically rigorous loan pricing analysis
About
RESOLUTE TRANSFER PRICING is a specialist advisory practice focused exclusively on the transfer pricing of cross-border intercompany loans.
We advise companies, accounting firms, and legal advisers on the structuring, pricing, and documentation of intercompany loans. Our work is grounded in OECD guidance on financial transactions and aligned with current international transfer pricing standards.
The practice is led by Kenique Ivery, a transfer pricing professional with an MSc in Finance, IBFD certification in intragroup financial transactions, and experience at Big Four firms advising multinational groups across Europe, Africa, North America, the Caribbean, and Asia.
By focusing on a single area — intercompany loan pricing — the practice delivers technically rigorous and commercially grounded analysis. Each engagement is tailored to the specific facts of the loan, the financial position of the borrower, and the relevant tax environment.
Our objective is straightforward: to ensure that intercompany loans are structured, priced, and documented in a manner that withstands scrutiny.
Contact Us
If you would like to discuss an intercompany loan pricing matter, please submit the form below.
We will respond promptly to arrange an initial discussion.