In assessing whether a controlled transaction is homogeneous, account is taken:
- the homogeneity of the transaction in economic terms, and
- the comparability criteria set out in the implementing rules and
- transfer pricing verification methods and
- other relevant circumstances of the controlled transaction.
In summary, the homogeneous nature of the transaction should be understood as the similarity of the subject matter of the transaction and other main parameters of the transaction that are relevant from the point of view of transfer pricing (such as e.g. important functions, assets, risks, as well as the way the price is calculated, relevant payment terms, etc.). If they are similar within several flows, the individual flows should be aggregated as one homogeneous transaction.