Do taxpayers need to consider whether intra-group loan arrangements are at arm's length?

Transfer Pricing
1

Do taxpayers need to consider whether intra-group loan arrangements are at arm’s length?

2

Yes, transfer pricing rules will apply to all transactions with Related Parties and Connected Persons. Therefore, any loan obtained from (or granted to) a Related Party or Connected Person needs to be at arm’s length (e.g. interest rate, duration, etc.).