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Chapter X paragraph 10.79

Another key consideration would be the likely consequences for other parts of the MNE group of supporting or not supporting the borrower. The criteria used to determine the status of an entity in this regard may include such considerations as legal obligations (e.g. regulatory requirements), strategic importance, operational integration and significance, shared name, potential reputational impacts, negative effects on the overall MNE group, general statement of policy or intent, and any history of support and common behaviour of the MNE group with respect to third parties. The relative relevance of those factors may vary from one industry to another.

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Chapter X paragraph 10.79 | 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>Another key consideration would be the likely consequences for other parts of the MNE group of supporting or not supporting the borrower. The criteria used to determine the status of an entity in this regard may include such considerations as legal obligations (e.g. regulatory requirements), strategic importance, operational integration and significance, shared name, potential reputational impacts, negative effects on the overall MNE group, general statement of policy or intent, and any history of support and common behaviour of the MNE group with respect to third parties. The relative relevance of those factors may vary from one industry to another. Related content: Netherlands vs Corp, October 2016, Supreme Court 16/01370 In this case company A had acquired the business (assets and liabilities) of another company, through an Acqui


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