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July 17, 2026
Article 125 introduces 'Transfer Pricing' concepts by defining related party transactions. It applies to transactions between a person and a 'related person', whether entered into directly or indirectly. Relationship is established if one party controls the other (per Articles 132-133), if both are under common control, or if they are relatives up to the third degree or connected by marriage. This broad definition ensures that the Tax Authority can scrutinize any deal where the parties may not be acting as independent entities, preventing the manipulation of profits through non-arm's length pricing.
Article 125
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