Dr. Brian Keegan:

It is an interesting point. The Deputy's conclusion, "if at all", is probably the answer. When we speak of transfer pricing, we are normally speaking about transactions between connected companies, most often those under common ownership. A REIT is by definition a kind of stand-alone management arrangement for a particular property or group of properties. Transfer pricing arrangements might conceivably apply if two REITs were in common ownership in different jurisdictions. I am not aware if that is a common structure. They are probably separate issues and I do not see any immediate interaction between the two.