A clear commitment to the arm’s lengths principle also for financial transactions would be appreciated. Focus of the TPG should be the “right” pricing of financial transactions and not the right level of the capital structure as such. In order to avoid controversy in this complex area the burden of proof for potential re-characterization of transactions (e.g. loan to equity) should be on the side of the tax authorities and applied only in limited case. In order to minimize the compliance burden and risk of controversy, OECD should consider to introduce reasonable materiality thresholds and safe harbours for certain transactions.