Commentary

B4.133 Arm's length pricing—comparable uncontrolled price

Business tax
Business tax | Commentary

B4.133 Arm's length pricing—comparable uncontrolled price

Business tax | Commentary

B4.133 Arm's length pricing—comparable uncontrolled price

Once a comparability analysis has been performed which determines the conditions and economically relevant factors of the controlled transaction (see B4.131), these conditions and factors can then be compared with those of comparable transactions of independent enterprises in order to determine an arm's length price. There are various ways to do this depending on the transaction type. The comparable uncontrolled price (CUP) method1 compares the price charged for property or services in a controlled transaction with the price charged in an uncontrolled transaction. There are two possible types of comparison:

  1.  

    •     internal CUP—the price

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial