This section describes a number of pricing approaches for those circumstances where a guarantee is found to be appropriate. However, when the accurate delineation of the actual transaction indicates that the purported guarantee is not a guarantee, other pricing approaches should be considered, in particular the guidance in Chapter VII. As in any other transfer pricing situation, the selection of the most appropriate method should be consistent with the actual transaction as accurately delineated, in particular, through a functional analysis. (See Chapter II).
TPG2020 Chapter X paragraph 10.169
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By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Financial guarantee, Financial transactions, Pricing guarantees, Treasury functions
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