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DEBT TRANSFER PRICING  

Assumptions

GCA professionals approach each advisory engagement by drawing upon extensive expertise in corporate finance, debt capital markets and ratings advisory. That said, GCA's specialists are neither tax accountants, nor tax lawyers, and as a result any Issuer will be expected to seek counsel from accounting and tax specialists in reaching a final conclusion with respect to optimal intercompany debt strategies.

Following guidelines set forth by the OECD as well as most national taxing authorities, GCA seeks to determine the ability of an Issuer (usually a subsidiary of a multinational corporation) to raise debt capital as a standalone entity in the public markets. For purposes of our analysis, and depending on instructions from our client, GCA may or may not consider the potential impact of implicit or explicit parental support after first determining the Issuer’s standalone Implied Credit Profile (ICP), which is analogous to a rating, Should an implicit support analysis be requested, the degree of implicit support is fact specific and would be determined in light of the protocols and guidelines established by the major rating agencies at the time of the debt transaction(s).

To perform the above analyses, GCA will assume the availability of:

  • full financial statements for the prior three fiscal years (with applicable notes)
  • outlook for the current fiscal year, and
  • the strategic plan forecast for the Issuer.

When audited historical financial statements are not available, unaudited financial statements may be relied upon. In such instances, however, GCA would expect the Issuer's accounting firm to have reviewed the methodologies employed and be comfortable with our reliance on these financials to form the basis of our credit profile opinion.

Confidentiality of all non-public information, including forecasts and projections, is covered via a mutually agreed Confidentiality Agreement.

 
 
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