The AOA seeks to attribute to a permanent establishment, or branch, the profits that it would have earned at arm’s length if it were a legally distinct and separate enterprise performing the same or similar functions under the same or similar conditions. Therefore, it incorporates separate entity and arm’s length principles. The aim of the AOA is to apply to intra-company ‘dealings’, i.e. dealings among separate parts of a single enterprise, transfer pricing principles that apply to inter-company transactions, i.e. transactions between different, albeit associated, enterprises.