[INTM514030] Thin capitalisation: practical guidance: knowledge and negotiation: formulating an arm's length position – comparables and OECD guidance
The arm's length range
As discussed in INTM514020, there is no single, correct answer to the question of what constitutes the arm's length position in a particular case, and for thin capitalisation it is particularly difficult to establish an arm's length price by the use of comparables, since there is scope for many variations, and it may be difficult to agree on the relative weight of any differences. Nevertheless, where comparables of reasonable accuracy do exist, they may be used as a starting point for discussing the position in a particular case. They may, for example, narrow down the range of possible values to one which can usefully be discussed.
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