Paper on pricing related party debt for banks that will be shared with the OECD in March 2018. We discuss the issue of intra-group lending which can be significant for global banks. They must adhere to arm’s length principles when conducting such intra-group lending. We argue that there needs to be flexibility to determine the arm’s length price. The Revenue Authorities should accept a number of different alternative approaches, including using external issuances or pricing from an internal mechanism (such as a yield curve).

IntraGroup lending_30 January 2018