Compulsory conversion of debentures into equity does not by...

Compulsory conversion of debentures into equity does not by itself establish a nil arm's length price for contractual interest payable before conversion. Transfer pricing must identify the contractual rights and apply an appropriate method; currency, tenure, credit risk, conversion terms and non-redemption affect comparability. Exceptional recharacterisation requires an established basis, such as a divergence between economic substance and legal form or an arrangement that is commercially irrational and impedes pricing. Rejecting an unsupported nil-price adjustment does not establish that the contractual coupon is arm's length. Ordinary deductibility, capitalisation and statutory interest-deduction limits require separate examination.