48.1 All transactions between the Company and its Affiliates shall be conducted in accordance with the arm’s length principle per the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Where there is any inconsistency between the Applicable Law governing transfer pricing and the OECD Guidelines, the Applicable Law shall prevail.

48.2 Upon request by the Authority, the Company shall provide to the Authority documentation, including copies of all contracts, evidencing the prices, discounts, and commissions related to any transaction between the Company and its Affiliates, as well as other relevant documentation related to transactions with Affiliates, including evidence of third-party transactions needed to determine the real arm’s length price for a like transaction.

For more information: See generally IISD, 2014, Section 7.6 (Transfer Pricing); Cotula, 2016, Section 3.3 (Taxation).