In this episode of Uncontrolled Opinions, hosts Mikhail and Silvana are joined by their colleague Martin Ibarguren, an experienced transfer pricing practitioner with deep expertise in intercompany (IC) financial transactions. Together, they dive into the foundational elements of transfer pricing and documenting intragroup loans. From determining whether a transaction is truly “debt” vs. “equity” to handling limited data for benchmark analyses, this discussion highlights the key factors and practical challenges that transfer pricing economists grapple with when establishing arm’s length interest rates for intercompany loans.