Topic collection
Core principles
The arm's length principle, associated enterprises, and comparability sit underneath every method, every benchmark, and every dispute. Start here before anything else.
Arm's length principle
7 minThe rule that transactions between related companies should be priced as if the parties were independent.
Associated enterprises
4 minTwo enterprises are associated when one participates in the management, control or capital of the other, or the same persons do so for both.
Controlled transaction
4 minA transaction between two associated enterprises, and therefore the unit that transfer pricing rules test.
Comparability analysis
8 minThe process of finding uncontrolled transactions or companies similar enough to test whether a controlled outcome is arm's length.
Permanent establishment (PE)
5 minA fixed place of business, or dependent agent activity, through which an enterprise becomes taxable in another country.
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