The presence of minority shareholders may be one factor leading to the outcomes of a taxpayer’s controlled transactions being closer to arm’s length, but it is not determinative in and of itself. The influence of minority shareholders depends on a number of factors, including whether the minority shareholder has a participation in the capital of the parent company or in the capital of a subsidiary, and whether it has and actually exercises some influence on the pricing of intra-group transactions.
TPG2017 Chapter III paragraph 3.26
Category: A. Performing a comparability analysis, OECD Transfer Pricing Guidelines (2017), TPG2017 Chapter III: Comparability Analysis | Tag: Comparability analysis, Comparable Uncontrolled Price (CUP) Method, Comparing to other controlled transactions, Presence of minority shareholders« Prev | Next »
TPG2017 Chapter III paragraph 3.25