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Question

Chapter X paragraph 10.77

In the context of intra-group loans, this incidental benefit that the MNE is assumed to receive solely by virtue of group affiliation, is referred to as [...]. The effect of potential group support on the credit rating of an entity and any effect on that entity’s ability to borrow or the interest rate paid on those borrowings would not require any payment or comparability adjustment. See Example 1 at paragraphs 1.164 – 1.166 of Chapter I and Section D.3.

Answer
implicit support

Question

Chapter X paragraph 10.77

In the context of intra-group loans, this incidental benefit that the MNE is assumed to receive solely by virtue of group affiliation, is referred to as [...]. The effect of potential group support on the credit rating of an entity and any effect on that entity’s ability to borrow or the interest rate paid on those borrowings would not require any payment or comparability adjustment. See Example 1 at paragraphs 1.164 – 1.166 of Chapter I and Section D.3.

Answer
?

Question

Chapter X paragraph 10.77

In the context of intra-group loans, this incidental benefit that the MNE is assumed to receive solely by virtue of group affiliation, is referred to as [...]. The effect of potential group support on the credit rating of an entity and any effect on that entity’s ability to borrow or the interest rate paid on those borrowings would not require any payment or comparability adjustment. See Example 1 at paragraphs 1.164 – 1.166 of Chapter I and Section D.3.

Answer
implicit support
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Chapter X paragraph 10.77 In the context of intra-group loans, this incidental benefit that the MNE is assumed to receive solely by virtue of group affiliation, is referred to as implicit support. The effect of potential group support on the credit rating of an entity and any effect on that entity’s ability to borrow or the interest rate paid on those borrowings would not requir

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Chapter X paragraph 10.77 | TPguidelines.com
oans, Chapter X: Financial Transactions, OECD Transfer Pricing Guidelines (2017) | Tag: Effect of group membership, Financial transactions, Intra-group loans, Treasury functions « Prev | Next » <span>In the context of intra-group loans, this incidental benefit that the MNE is assumed to receive solely by virtue of group affiliation, is referred to as implicit support. The effect of potential group support on the credit rating of an entity and any effect on that entity’s ability to borrow or the interest rate paid on those borrowings would not require any payment or comparability adjustment. See Example 1 at paragraphs 1.164 – 1.166 of Chapter I and Section D.3. Related content: Finland vs. Corp. November 2010, Supreme Administrative Court HFD 2010:73 A company, which belonged to a Nordic group, had until August 2005, two loans with an independ

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