The international standard that OECD member countries have agreedshould be used for determining transfer prices for tax purposes. It is set forthin Article 9 of the OECD Model Tax Convention as follows: where“conditions are made or imposed between the two enterprises in theircommercial or financial relations which differ from those which would bemade between independent enterprises, then any profits which would, butfor those conditions, have accrued to one of the enterprises, but, by reason ofthose conditions, have not so accrued, may be included in the profits of thatenterprise and taxed accordingly”.