Accordingly, this guidance is not intended to prevent countries from implementing approaches to address the balance of debt and equity funding of an entity and interest deductibility under domestic legislation, nor does it seek to mandate accurate delineation under Chapter I as the only approach for determining whether purported debt should be respected as debt.
TPG2020 Chapter X paragraph 10.9
Posted on | By OECD
Category: OECD Transfer Pricing Guidelines (2017) | Tag: Domestic legislation, Financial transactions, interest deductibility, Interest limitation, Other approaches may be taken, Thin Capitalisation (Thin Cap)
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