[法律资料]Transfer Pricing - Intercompany Loans and Guarantees.pdf

Asia Pacific Tax Presents: Transfer Pricing . Intercompany Loans and Guarantees: New Rules and Directions for the Asia Pacific Region Keith Reams / Geoff Gill / Timothy O‟Brien 16 July 2008 Agenda • The current financing environment • Financing and transfer pricing in Asia Pacific – risks / opportunities • Loans – pricing issues • Thin capitalisation and transfer pricing – current controversies • Guarantees – pricing issues and controversies • Leasing arrangements • Trading arrangements • Insurance • Questions answers Copyright © 2008 Deloitte Touche Tohmatsu. All rights reserved. The current global financing environment • Cost of funds − Significant variances in base rates between major markets − Short term interbank finance (e.g. LIBOR) generally high relative to cash rates in many markets − Credit spreads generally up (particularly for low rated debt) • Uncertainty about supply − Global losses from financial institutions currently $250bn (and rising…) − Bank lending criteria have been tightened - effect on supply − Potentially credit rationing situation - but are we over the worst of it? • Asia Pacific region not immune to this – ripple effects felt globally Copyright © 2008 Deloitte Touche Tohmatsu. All rights reserved. Credit spreads widened significantly in 2007/08 US Industrial 5 year Spread (over Treasury Bonds) 7.00 6.00 5.00 Spread (%) 4.00 3.00 2.00 1.00 30-Jun-08 31-Mar-08 0.00