What are the additional criteria for determining Related Party?
Related Party also means any of the following ties-
a Person and its Permanent Establishment (‘PE’) or Foreign PE meaning that TP rules apply to transactions between a Person and their PE or Foreign PE;
two or more Persons that are partners in the same Unincorporated Partnership; and
a Person who is the trustee, founder, settlor, or beneficiary of a trust or foundation and the trust or foundation, including the trust’s or foundation’s Related Parties.