Uncontrolled Opinions9 Des 2025

Interco Financing and Swaps

In this episode, Mikhail and Silvana welcome Adriaan van der Heijden from Quantera Global, a specialist in financial transaction transfer pricing.

Part 1 — Intercompany Financing: Foundations, Challenges & Evolving Practice

In Part 1, Mikhail and Silvana sit down with Adriaan to explore how intercompany financing has evolved with OECD Chapter 10, new local rules, and growing audit scrutiny. They discuss the core elements of a sound financial transaction analysis—accurate delineation, debt capacity, two-sided assessments, options realistically available, substance, and governance—and walk through practical challenges that in-house teams and advisors face. If you want a clear, practical overview of today’s IC financing landscape and best practices, Part 1 sets the foundation.

Part 2 — Use of Swaps for comparability adjustments & Local Perspectives (US & EU)

Part 2 dives into the tools and data behind benchmarking intercompany loans. Adriaan explains swaps in plain language—fixed-to-floating and cross-currency—and how they help practitioners make comparability adjustments when market data is imperfect or illiquid. The conversation also covers bond vs. loan market data, reliability of secondary market yields, and how different jurisdictions (US vs. Europe) view methods, safe harbors, and evidence. Part 2 is a practical guide for anyone dealing with real-world constraints in financial transaction TP.

*****
Adriaan van der Heijden
https://www.linkedin.com/in/adriaan-van-der-heijden-23522494/

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