The Guide pays special attention to the search for comparable transactions between unrelated parties. The following have been designated as comparability criteria impacting loan interest rates that must be taken into account:
- Issue date
- Country of the borrower
- Type of interest rate
- Industry of the borrower
- Other factors capable of influencing the pricing of transactions for issuing financing, e.g., option of early repayment / demand for repayment of a loan.
Unlike the recommendations published by the OECD, the Guide does not describe the principles to be followed for the correct determination of the terms of financial transactions. In particular, the Guide does not review the procedure for recognizing intragroup financing as a loan in substance (to assess the probability that a loan will be reclassified as an equity contribution), nor does it comment on the identification of commercial and financial conditions or the economically significant characteristics of financial transactions.
In addition, the Guide, unlike the OECD Guidelines, includes a detailed example of a comparability adjustment of the tenors of potentially comparable transactions to make them consistent with the tenor of an analyzed transaction.