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The Pitfalls Of Debt Transfer Pricing
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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 to raise debt capital as a stand-alone entity in the public or private markets. For purposes of our analysis, GCA assumes that no explicit or implicit parental support exists and that the Issuer should be viewed as a pure stand-along entity bearing no relationship to its parent other than that of an equity holder with interests and objectives similar to that of a private equity firm.

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.

GCA will also assume availability of management for due diligence meetings, both in-person as well as via follow up conference calls, to augment publically and privately available information.

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

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