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13.4.1. Main Rules

The arm’s-length principle (ALP) rule is codified in the Aruban State Ordinance Profit Tax (SOPT).

If a corporate entity participates, directly or indirectly, in the management, supervision, or the capital of two or more corporate entities, the conditions related to all transactions between these affiliated parties should be at arm’s length. The ALP is applicable on all transactions between affiliated companies like purchase prices, management fees, remunerations for services provided, royalty payments, etc.