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77

Rules 2026 · Rule 77

Meaning of expressions used in determination of arm's length price

Rules 77-130

Rule 77 defines the terms used in rules 77 to 84 on transfer pricing: associated enterprise, enterprise, property, services, transaction and uncontrolled transaction.

Definitions.

  • Associated enterprise has the meaning in section 162.
  • Enterprise has the meaning in section 173(b) and, for a specified domestic transaction, includes a unit, an enterprise, an undertaking or a business of a person who undertakes the transaction.
  • Property includes goods, articles or things and intangible property.
  • Services include financial services.
  • Transaction includes a number of closely linked transactions.
  • Uncontrolled transaction means a transaction between enterprises other than associated enterprises, whether resident or non-resident.