Case analysis evaluates intra-group financing and borrower debt capacity, highlighting conditions under which related-party loans are recharacterized as equity for tax purposes.
This article examines the transfer pricing treatment of intra-group financial transactions, with a particular focus on the borrower’s borrowing and repayment capacity. Through both theoretical analysis and a practical case study, it considers when related-party financing may be respected as debt and when it may instead be recharacterized as equity for tax purposes.
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J. Collado (2026) studied this question.
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