The fixed ratio in the BEPS action is total debt. Both intra-company and external.
No. i read it, but i don't get it - how you come to conclusion BEPs A4 will have no impact, by only looking at an external debt example?
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Intra-company loans + bank debt is not > intra company loans.
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Sorry. I must be misreading as I don't follow this. If ICL are say 100 and BD 100 then surely 100+100 is greater than 100?
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