Academy · Practice track
Intra-group financing
Pricing a related-party loan and defending the rate
A loan between group companies is priced twice: once when it is signed, and again when an auditor reads it. This course prepares the second reading at the time of the first.
- Track
- Practice
- Format
- 6 lessons · case file · model memo · quiz
- Access
- 12 months
- Price
- €149
- Status
- In production
A marked assignment can be added for €89. Prices exclude VAT. Gumroad adds the VAT of your country at checkout and issues the receipt.
After the course you can
- decide whether an advance is a loan at all, or equity with an interest clause;
- rate a borrower that no agency has ever rated;
- price the interest and show the comparables behind it;
- treat cash pools and guarantees without paying for the same risk twice;
- test the interest against the 30% EBITDA limit before it is deducted;
- assemble the loan section of a local file.
Lessons
-
01
Is it a loan?
Accurate delineation under Chapter X of the OECD Transfer Pricing Guidelines: the terms, the parties' conduct, the borrower's capacity to repay — and when the answer is equity.
-
02
The borrower's credit rating
Stand-alone and group ratings, implicit support, and how to rate a company no agency has looked at.
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03
Pricing the rate
Comparable loans, bond yields and loan databases; the interquartile range, and why the median is not automatically the answer.
-
04
Cash pools and guarantees
Who bears the risk, who earns the fee, and how the pool leader is rewarded.
-
05
Interest limitation
Article 4 of Council Directive (EU) 2016/1164: the 30% EBITDA ceiling, the €3 million threshold, and how both sit alongside the arm's length test.
-
06
The file
The loan agreement clauses that matter, the local-file section, and the documents an auditor asks for first.
Figures are illustrative
The worked case
A Latvian operating company lends €2 million to its Estonian sister company for five years at a fixed 3%. There is no security and no repayment schedule, and nobody has paid interest since the second year.
The course takes that file through every lesson: whether it is still a loan, what rate an independent lender would have asked, what the unpaid interest means under two distributed-profits systems, and what the file should have held from the first day.
Who it is for
- Group finance teams that lend between entities
- Accountants preparing transfer-pricing documentation
- Advisers answering an auditor's question on interest
