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.
TPG2022 Chapter X paragraph 10.9
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Category: OECD Transfer Pricing Guidelines (2022), TPG2022 Chapter X: Transfer Pricing Aspects of Financial Transactions | Tag: Domestic legislation, Financial transactions, interest deductibility, Interest limitation, Other approaches may be taken, Thin Capitalisation (Thin Cap)« Prev | Next »
- TPG2022 Chapter X paragraph 10.8 Although this guidance reflects an approach of accurate delineation of the actual transaction in accordance with Chapter I to determine the amount of debt to be...