Of these constraints, exchange controls have given cause for more particular comment. Problems may arise for example because exchange controls effectively prevent an associated enterprise which has received a loan from transferring abroad the interest payments as they fall due, thus possibly throwing doubt on the treatment of the interest for tax purposes. While there may be room for more than one solution in both the country of the borrower (which may or may not regard the un-transferred interest as having been paid) and the country of the lender (which may or may not be deemed to have received interest not transferred) it is considered that there is no justification for treating blocked payments differently for tax purposes when they occur, between associated enterprises from the way in which they would be treated if they occurred between unrelated enterprises. It is however considered that exchange control regulations in a country should not preclude the deduction for tax purposes, for either associated or unrelated enterprises, of payments due to persons outside that country, although it is recognised that the tax authorities of the other country may have to take the effects of these regulations into account ...

The prices charged for goods, services, etc. transferred bet ween associated enterprises in different countries may be affected by, for example, Government interventions in the form of price control, or subsidies to particular sectors, or by exchange control or exchange rate policies. It should be observed that the same considerations would apply to transactions between unrelated enterprises and that they would usually influence the prices in such transactions ...