PROFIX HELLAS provides Transfer Pricing documentation services.
We have considerable and many years of experience in Transfer Pricing documentation.
We can help you design, implement, evaluate, document and defend transfer pricing policies for domestic and international transactions between your related entities.
Arm’s Length Principle
(Article 9 of the OECD Model Tax Convention)
[Where] conditions are made or imposed between the two [associated] enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly.