What is “Control”?  Nope we are not talking about Janet Jackson’s song.  The raison d’etre in TP is pricing of “Controlled Transactions”. So, what is control?  

In this episode of Uncontrolled Opinions, hosts Silvana and Mikhail dive into the definition of  “control”  in the context of transfer pricing. We discuss the differences between “Control” and “Related Parties”. We also highlight different definitions and ownership thresholds for what constitutes control and/or related party.  We also examine the practical implications of these divergent definitions on transfer pricing benchmarking. 

01:08 Defining control in TP

01:51 Difference between “Control” and “Related Parties”

06:16 Regulatory definitions and how they can differ across countries.

11:15 Practical challenges in TP benchmarking

14:32 Opportunity for harmonizing definitions 

23:23 Practical implications and future outlook