# Transfer Pricing

This open-bank protocol covers the general governance layer for controlled transactions between Fiscal Hosts, in the case of verified members of the Open Constitution AI Network E-tenancy for the benefit of the affiliated beneficiaries.

Transfer pricing is non-contextual for the exchange of values between E-residents.&#x20;

Transfer Pricing Protocol requires adherence to other Open Protocols at all times and is generally undertaken at arm's length. No subsidy or discount is allocated to any transfer pricing.&#x20;

{% hint style="info" %}
*A. Each case using Transfer Pricing protocols should also ensure protocol compliance by Fiscal Hosts with:*\
1\. DTAA compliances&#x20;

2\. VAT compliances

*B. Each case using transfer pricing protocols should ensure that the monetary benefit in value of the controlled transactions is above(read includes) any case processing cost.*

*C. Each case using transfer pricing protocols should ensure that the socio-economic benefit in value of the "controlled transactions" is directed at a majority of the population size of the foundation (more than 50%).*
{% endhint %}


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