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ConceptUK · IE · UAEReviewed October 2026
A loan between companies in the same group, often across borders, used to fund one company from another. The interest rate and terms have to be defensible, because tax authorities test them against what independent lenders would have agreed.
It sits where transfer pricing meets thin-capitalisation rules: mispriced or excessive intra-group debt can have its interest deduction denied or be recharacterised.
A definition of an established legal or tax concept for general information. It is not advice on any individual situation.
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