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NEWS & ANALYSIS
US Transfer Pricing Rules for Intercompany Loans - A Practical Overview for SMEs
Intercompany loans are a frequent and relatively straightforward area of challenge in US transfer pricing audits. Unlike more complex transfer pricing issues, related-party debt arrangements lend themselves to mechanical adjustments when basic legal, pricing, or behavioral requirements are not met. This note summarizes the key US transfer pricing rules that apply specifically to intercompany loans and highlights how the IRS approaches these arrangements in practice, particula
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