OECD To Address Arm's-Length Price, Not Debt Vs. Equity

By Molly Moses (July 17, 2019, 5:39 PM EDT) -- The OECD's coming transfer pricing guidelines on financial transactions will focus on how to determine an arm's-length price but not provide guidance on whether financing between related parties constitutes debt or equity, an IRS official involved in the project said Wednesday.

Those working on the project are trying to provide guidance on how to determine an arm's-length price for such transactions rather than settling the question of characterization, said Chris Bello, chief of Branch 6 in the Internal Revenue Service Office of Associate Chief Counsel, International, at a conference hosted by the National Association for Business Economics in Washington, D.C....

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