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Which factors define comparability of transactions between related persons?

To define comparability between separate transactions and transactions related to persons, the following factors should be reflected:
  • Features of transferred assets or services provided
  • Functional profile (i.e. functions performed, assets employed and risk assumed)
  • Contractual terms of transactions
  • Economic factors followed by concerned parties
  • Business strategies followed by concerned parties
  • Any other economically relevant aspect of the transaction.
(Additional details can be found in the Transfer Pricing guidelines.)