Related Parties as Used in Transfer Pricing

There is a need to provide more clarity about the meaning of the term “associated enterprise” in article 9 of the OECD Model Tax Convention (OECD Model), as it serves the objective of the elimination of economic double taxation and ensures that transactions between associated enterprises are conducted at arm’s length. Given the increasing focus on transfer pricing, a rise in the number of transfer pricing disputes is expected, and correspondingly article 9 of the OECD Model and the relevant tax treaties will be applied more often and to a greater extent to eliminate economic double taxation.