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.)
