Fwsxcs (1.{o.2) No.9 201s (2) In applying the provisions of paragraph 3 to a transaction involving the licence, sale or other transfer of intangible property, consideration shall be given to any special factors relevant to the c omparability of the controlled and u ncontrolled trans action s, i nc ludin g (a) the expected benefits from the intangible property; ancl (b) any geographic limitations on the exercise of rights to the intangible property; and the exclusive or non-exclusive character of the rights (c) transferred; and (d) whether the transferee has the right to participate in further developments of the intangible property by ttre transferor. for domestic trctnsactions l l . Where an adjustrnent is made by the Cornmissioner under Corcespondin g adj u strnents section 988 to the taxable income of a taxpayer in relation to a clomestic transaction, then, the Commissioner shall make an appropriate adjustment to the taxable incorne of the other party to the transaction. Co rresponding adju stments fo, inte rnatictnal transactions L2.(1) A service charge between a taxpayer and an associated person shall be considered consistent with the arm's length principle lvhere(a) an adjustment to the conditions of transactions between a person resi.dent in Ztmbabwe and an associated person is made or proposed by a tax administration in a country other than Zimbabwe; and (b) this adjustment results in the taxation in that other country of an amount of income on which the person resident in Zimbabwe has already been charged to tax in Zimbabwel and (c) the country making or proposing the adjustment has a treaty rvith Zimbabrve that reflects an intention to provide for the relief of economic double taxation. (2) The Commissioner, shall after a request is made by the person resident in Zimbabwe, examine the consistency of that adjustment with the arm's length principle provided for under section 988, consulting as necessary with the competent authority of the other country. (3) If the adjustment proposed or made by the other country is consistent r,vith the arm's length principle both in principle ancl as regards the amount, the Comrnissioner shall make a corresponding adjustrnent to the amonnt of the tar charged in Zirnbabrve to that person ou thcse profits, in orcler to eliminate the econornic double taxation that lvould result from the inclusion of the salne profits in the taxable income of both that person and the associated person. (4) Arequestunder subparagraph (2) must include the information necessary for the Commissioner to exanrine the consistency of the adjustrnent made by the tax administration of the other country r,vith the arm's iength principle, including -_ (a) the name, registered address and, where applicable, traclittg narne(s) of the related person; and (b) evidence of the tax residence of the related person; 190