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Answer: Transfer Pricing is a pricing system related to the transfer of goods, services and intangible assets between a business group within a multinational group of companies. Transfer pricing transactions can occur between multinational companies and subsidiary companies either in their own country (local transfer pricing) or transnational abroad (cross border) . This transaction is called a controlled transaction (controlled transactions) or related transactions (related party transactions) . The selling price of a product that the parent company applies to the subsidiary may differ from the sale price of the independent party . This sale price is referred to as a transfer price. Article 9, OECD On Income and On Capital Tax Convention Model - OECD defines related companies are: A company that is directly or indirectly involved in the management, control or capital of a company; or Both companies are under the same control Section 139 of ITA 1967 provides that control is a controlling power of the company (directly or indirectly). Such authority is obtained by way of shareholding, voting power, power embodied in the procedure of the company or other document relating to the company.