Christopher Okafor, Managing Partner, Fairgate Solicitors, Legal Practitioners and Tax Advisory Port Harcourt, Nigeria, in his article, Intra-Group Loan Under the 2020 OECD Guidelines: When the Arm’s Length Defies Accuracy in Measurement, We May Look for a Formula, argues that the worry about intra-group loan transactions is its amenability to abuse by the transfer of the cost of fund to high tax jurisdiction and the consequent transfer of earnings from interests to low or nil tax jurisdiction. The abuse distorts economic realities, and the arm’s length approach to transfer pricing is seemingly unable to fit in transactions on intangible mobile assets. Though the Organization for Economic Cooperation and Development (OECD) has produced a new Guidance in 2020 to regulate intra-group loan, it is moot whether the guidance is a veritable answer to the mobility and fungibility of financial assets. Christopher proposes an alternative to the arm’s length principle. In his words, intragroup loan deserves a second look and a comparative analysis on the levers of arm’s length principle and formulary apportionment–an excursion from what is, arm’s length principle to what we think should be, formulary apportionment.