Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expansion capacity.

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....Negative liens over participating interests in oil and gas blocks and related receivables, created to secure associated enterprises' borrowings, are treated as international transactions where they restrict the asset-owning entity's ability to charge, borrow against, or expand using its operating assets. A lender's security interest may continue despite the borrower entities' bankruptcy. Arm's-length pricing must reflect the negative lien's factual character and resulting impairment of borrowing capacity; averaging bank-guarantee rates or applying loan-benchmarking approaches is not appropriate. The arm's-length price requires fresh determination under applicable transfer-pricing provisions.....