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Transfer Pricing

Related parties and connected persons explained

02 Aug 2026·5 min read

The definitions are broader than many owners expect and include individuals as well as companies.

Related parties

Entities under common ownership or control, and those where one party can exercise significant influence over the other, are related parties.

Connected persons

Owners, directors and their relatives, along with entities they control, may be connected persons. Payments to them, such as salaries and loans, can be scrutinised.

Why it matters

Excessive payments to connected persons may be non-deductible. Pricing at market rates and documenting it avoids disputes.

Key takeaways
  • Map owners and directors to transactions
  • Charge market rates for loans and services
  • Document agreements in writing

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