Joris Steunenberg and Mick Willemsen have written three technical articles on the use of credit ratings by transfer pricing practitioners and tax authorities, which are published on TP Week in the coming weeks as a mini-series.
The technical articles concern the following:
(i) This first article discusses OECD guidance on the subject and how the business risk profile and financial risk profile form the “anchor rating” of an entity.
(ii) The second article provides guidance on the determination of an entity's stand-alone credit profile. This article will be published in week 34.
(iii) The final article in this series, describes the impact of passive association with an MNE group and the effect it may have on the creditworthiness of an entity (i.e. implicit support). This article will be published in week 35.
The first article can now be accessed via the following link: https://www.tpweek.com/articles/tp-and-credit-ratings-determining-the-anchor-rate/arfjruve
However, as not all interested parties may have access to the website of TP Week, parties can sign-up for free trial on the TP Week website.
In addition, the first article can also be accessed here.