13 November 2025

We are seeing early- and even late-stage groups still booking interest-free related-party loans to “keep things simple.” 𝐁𝐮𝐭 𝐭𝐚𝐱 𝐚𝐮𝐭𝐡𝐨𝐫𝐢𝐭𝐢𝐞𝐬 𝐬𝐞𝐞 𝐬𝐨𝐦𝐞𝐭𝐡𝐢𝐧𝐠 𝐞𝐥𝐬𝐞:(1) transfer pricing risk (not arm’s length) and (2) lost withholding tax where interest would otherwise be taxable. 𝐖𝐡𝐲 𝐭𝐡𝐞 𝐟𝐨𝐜𝐮𝐬 𝐧𝐨𝐰?• OECD guidance on financial transactions tightened expectations around pricing and substance.• […]