Episode 103: Pricing intercompany loans: why implicit support matters

April 04, 2024


In this TP Talks episode, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing practice) is joined by Tanja Keser (Partner, PwC Germany and EMEA Financial Transactions Transfer Pricing Leader), Aaron Okin (Principal in PwC’s US National Tax Services Transfer Pricing practice), and Bob Ritter (Principal in PwC’s Transfer Pricing practice and US Financial Transactions Transfer Pricing Leader) to discuss the recent administrative guidance issued by the IRS regarding implicit support  and its impact on the pricing of intercompany loan transactions from a US and global perspective. The speakers address what implicit support is and why it matters to the IRS, what impact the guidance may have on a taxpayer’s tax return position, and potential issues companies should consider.

Contacts: Kristina NovakTanja Keser, Aaron Okin, and Bob Ritter

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Horacio Peña

Global Transfer Pricing Leader, PwC United States

Tel: +1 (917) 478-5817

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