https://www.taxtmi.com/article/detailed?id=6967 Whether a corporate guarantee given to an associated enterprise is an international transaction depends on whether it has a real bearing on the guarantor's profits, income, losses or assets or constitutes a service conferring a benefit. One line of authority treats such guarantees as quasi capital or shareholder activity outside transfer pricing absent cost or invocation; the counter view treats guarantees as cross border services enhancing creditworthiness where costs, risk exposure or material financing benefit to the affiliate exist. Where adjustments are made, bank guarantee rates cannot be mechanically applied without a FAR analysis and appropriate adjustments. en-us Tue, 06 Sep 2016 11:28:14 +0530 Tue, 06 Sep 2016 11:28:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=6967 Whether a corporate guarantee given to an associated enterprise is an international transaction depends on whether it has a real bearing on the guarantor's profits, income, losses or assets or constitutes a service conferring a benefit. One line of authority treats such guarantees as quasi capital or shareholder activity outside transfer pricing absent cost or invocation; the counter view treats guarantees as cross border services enhancing creditworthiness where costs, risk exposure or material financing benefit to the affiliate exist. Where adjustments are made, bank guarantee rates cannot be mechanically applied without a FAR analysis and appropriate adjustments. Articles Income Tax Tue, 06 Sep 2016 11:28:14 +0530 https://www.taxtmi.com/article/detailed?id=6967