Duff & Phelps' Transfer Pricing Team Discusses Debt-Equity Characterization and OECD's Chapter X

Managing Directors Stefanie Perrella, Fabian Alfonso and Matt Billings and Directors George Condoleon, Andrew Cousins and Zachary Held in Duff & Phelps’ Transfer Pricing practice recently published an article for Bloomberg Tax titled, “INSIGHT: Debt Characterization and Application of OECD Accurate Delineation Analysis.” 

On February 11, 2020, the Organisation for Economic Cooperation and Development (OECD) released for the first time its highly anticipated transfer pricing guidance on financial transactions. Sections A to E of the report have been added to the OECD Transfer Pricing Guidelines as Chapter X. 

This article explores perspectives from select countries on their approach to debt-equity characterization and their alignment to Chapter X of the OECD Guidelines, including interaction of the local transfer pricing rules with other parts of local income tax law dealing with debt such as case law, thin capitalization rules and debt-equity rules where relevant.

Download the full article here.

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