Malik Hill

Transfer Pricing Loans and Financial Instruments Malik Hill

The author over the past few years, as a tax practitioner and transfer pricing petitioner has seen things change quite a bit and it is an area that is going to develop even more. In this monograph he will cover loan pricing and provide a full methodology along with examples and introduce the reader to the specificities of several European countries such as Italy, Luxembourg, the Uk or even France regarding loan pricing. Then, in the second part of this monograph M. Hill will focus on how to delineate and analyse transactions involving financial instruments and also tackle the difficulty of having the analysis challenged by the tax authority. Indeed, your concern as a practitioner should of course regard having the documentation that proves the transaction is actually comparable and provide reliable data, but you should also ask yourself the following question: "Does the tax authority have the ability to actually understand and replicate my analysis?".