不好翻译呀。。。。

正是不好翻译才来求助的！我也老头疼的！

段落来源于OECD2010，如下：    However,there are two particular circumstances in whichit may,exceptionally, be both appropriate and legitimate for a tax administration to consider disregarding the structureadopted by a taxpayer in entering into a controlled transaction. The first circumstance arises where the economic substance of a transaction differs from its form. In such a case the tax administration may disregard the parties’ characterisation of the transaction and re-characterise it in accordance with its substance. An example of this circumstance would be an investment in an associated enterprise in the form of interest-bearing debt when, at arm’s length, having regard to the economic circumstances of the borrowing company, the investment would not be expected to be structured in this way.

仅供参考。该段讲述关联方融资。最后一句话：举一个这种情况下的例子，根据借款人的经济环境按照独立交易原则，以收取利息的方式借款给关联公司，这种投资方式并不应该如此设计。