Business transactions are divided into 【
Related-party Transactions】 and 【
Independent Third Party Transactions】.
Related-party transactions occur when transactions are carried out between parties that are related to one another, such as transactions between a parent company and its subsidiaries or between entities within the same group.
In contrast, independent third-party transactions refer to transactions conducted between unrelated parties that have no connection or affiliation with each other. These transactions are entered into purely based on commercial considerations and are not influenced by any existing relationship between the parties.
In simple terms, transfer pricing refers to the pricing of transactions when related parties engage in transactions with one another. The transfer price should be comparable to the price that would have been charged between independent parties under similar circumstances.
Accordingly, businesses are expected to demonstrate that transactions between related parties are conducted in accordance with the arm’s length principle, meaning that the prices applied do not materially differ from market prices.