Our Firm
Leadership
Debt Private Placements
Debt Transfer Pricing
Executive Summary
Assumptions
Objectives and Scope
Implied Credit Profile
Indicative Pricing Assessment
GCA's Debt Transfer Pricing Team
Disclaimer - Notice to Recipient
The Pitfalls Of Debt Transfer Pricing
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DEBT TRANSFER PRICING  

Executive Summary

Continuing growth of multinational enterprises has inevitably led to the increasing need for issuers to comply with Debt Transfer Pricing regulations across a range of taxing jurisdictions. Global Capital Advisors, LLC ("GCA”) is uniquely qualified to offer issuers Debt Transfer Pricing Services that deliver expert evaluation of intercompany debt and associated interest expense deductions.

GCA's Debt Transfer Pricing Services are specifically tailored to multinational corporations with a subsidiary or subsidiaries (the "Issuer”) possessing material amounts of intercompany debt, giving rise to the need to justify both the amount and pricing of existing debt as well as the suitability of prospective debt issuance.

Defensible transfer pricing structures and associated interest expense deductions require, among other things, that Issuers secure two credible independent opinions substantiating the:

  • stand-alone credit profile of the Issuer; and
  • amount, pricing and structure of comparable financings for similar credits.

GCA's professionals bring a unique blend of credit rating and capital markets expertise to each engagement, applying these skills to developing both 1) an Implied Credit Profile for the Issuer and 2) an Indicative Pricing Assessment of implied public and/or private financing options for that Issuer.

Upon completion of our research and analysis, GCA's clients receive a Debt Transfer Pricing Report. This Report provides an in depth analysis of, and justification for, the Implied Credit Profile of the Issuer, along with an equally comprehensive Indicative Pricing Assessment based on market conditions and issuance opportunities for comparable credits.

The Implied Credit Profile contains an analysis of comparable companies with near-equivalent ratings from Moody's and S&P; while the Indicative Pricing Assessment factors in all relevant variables likely to impact pricing, including amount, maturities, covenants, ranking and call features typical for issuers looking to access the public or private markets with the assumed Implied Credit Profile.

GCA has priced over $8 billion worth of intercompany debt on behalf of numerous European multinationals including clients that represent a broad cross-section of the FTSE 100.

 
 
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