Transfer pricing is the most problematic tax issue for multinationals here as well

The transfer price is the settlement price used between affiliated companies, so any company that enters into any transaction with an affiliated company must pay attention to the relevant rules. These must be accounted for at a market price that independent businesses would apply to their transactions between themselves. If the settlement price used differs from the market price, a correction must be made in order to determine the amount of corporate tax to be paid as if these transactions were concluded exclusively by independent parties.