Applying the Arm’s Length Principle to Intra-Group Financial Guarantees in light of the OECDs Draft guidance on Financial Transactions
1. Purpose of the blog Intra-group guarantees are usually used by companies within the same multinational enterprise to obtain beneficial conditions for funding arrangements. For instance, lower interest rates due to the decreased level of the credit risk assumed by the lender (such as a bank) or/and extended borrowing capacity. In this blog, we will…