Arm’s-length principle

The analysis considers the actual transaction and economically relevant circumstances, including functions, risks, assets, terms and market conditions. It is not necessarily a search for one identical publicly quoted price. Different methods or adjustments can be appropriate depending on comparability and the applicable framework. Distinguish a tax-pricing assessment from a management-accounting transfer price chosen to support internal decisions and motivation. A general explanation does not establish a particular jurisdiction’s exemptions, documentation duties or accepted result; these require the current rules and evidence for the transaction.