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How to Make Intercompany Loans BEPS Proof

Updated: Oct 9, 2023

By Steef Huibregtse, Virender Sharma and Maria Grigoryeva.


Debt as intercompany financing with excessive interest deductions has come under greater scrutiny of the tax authorities after the OECD published its final work on Action Points relating to intercompany financing in October last year. In the light of the aforementioned, and the current practice of MNEs on intercompany loans, this article delves into 4 “true or false” statements which are relevant for various stakeholders including MNEs to ponder over.


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