Transfer pricing continues to be a crucial international issue for businesses worldwide. It is a concept applicable to controlled transactions which are considered to be cross-border transactions between related parties. Related parties include not only parties within the same group, but also parties which have a link of direct or indirect control, including control over the board of directors.
Transfer pricing deals with determination of the prices charged in transactions performed between related companies. Transactions between related parties should observe the arm's length principle. As such, prices charged in related party transactions should not differ from prices charged in third party transactions under comparable circumstances (market value).
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