The Commissioner-General may consider the following key factors when evaluating whether price manipulation exists between connected persons:

1. Contractual terms:
   The Commissioner-General will compare the terms of the contract under the controlled transaction (between connected persons) with those under an uncontrolled transaction. If the contractual terms are similar, it is expected that the prices will also be the same or similar. Any significant deviation in pricing between controlled and uncontrolled transactions may raise suspicions of price manipulation.
   (2.5 marks)
2. Nature of the product or service:
   The Commissioner-General will examine whether the products or services involved in the controlled transaction are the same or similar to those in an uncontrolled transaction. If there are material differences in the nature of the products or services, these may justify different prices. However, if the products or services are similar, any significant price difference may indicate price manipulation.
   (2.5 marks)
3. Function, Asset, and Risk (FAR) analysis:
   The Commissioner-General will evaluate whether the functions performed, assets employed, and risks assumed by the parties in the controlled transaction are comparable to those in an uncontrolled transaction. Differences in these factors may justify different pricing. If the FAR analysis shows that the transactions are comparable, the prices should be comparable as well.
   (2.5 marks)
4. Economic circumstances:
   The Commissioner-General will consider the economic environment in which the controlled and uncontrolled transactions take place. This includes factors such as interest rates, inflation, exchange rates, and market conditions. If the economic circumstances are similar, the prices in both transactions should be similar. Significant differences in prices under similar economic conditions may indicate price manipulation.
   (2.5 marks)