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13.4.2. Specific TP Issues

Transactions related to services are considered at arm’s length, if following conditions are fulfilled:

  • Services are actually rendered;
  • Services provide economic and commercial value to the recipient;
  • An enterprise would have paid, under same or similar circumstances, for such services if provided by an independent enterprise or if performed in-house; and
  • Price / value of such services corresponds to prices if agreed between independent enterprises for similar services under similar circumstances.