In some circumstances taxpayers may seek to evidence the arm’s length rate of interest on an intra-group loan by producing written opinions from independent banks, sometimes referred to as a “bankability” opinion, stating what interest rate the bank would apply were it to make a comparable loan to that particular enterprise.
TPG2020 Chapter X paragraph 10.107
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Bank opinion, Financial transactions, Interest rate, Intra-group loan, Loan, Treasury functions
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