Understanding the Comparable Uncontrolled Price (CUP) Method in Transfer Pricing

This article relates to the following articles:

• Essential Components of Transfer Pricing Documentation
• The Importance of Thorough Economic Analysis in Transfer Pricing

The Comparable Uncontrolled Price (CUP) MethodThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed... is one of the primary transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... methods used to determine arm’s length prices for transactions between related entities. When sufficient data is available, it is considered the most direct and reliable way to apply the arm’s length principle. 

What is the Comparable Uncontrolled Price (CUP) Method?

The CUP methodThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed... compares the price charged for property or services transferred in a controlled transaction to those charged for comparable property or services in an uncontrolled transaction under similar circumstances. It is one of the five transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... methods recommended by the Organization for Economic Cooperation and Development (OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD's core mission is to promote policies that improve...) and is widely accepted by tax authorities worldwide.

There are two types of CUPThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed... methods:

1. Internal CUPThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed...: The internal CUP methodThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed... involves using comparable transactions within the same company. For instance, if a company sells a product to both related and unrelated parties, the price charged to the unrelated parties can serve as a benchmarkBenchmarking, within the context of transfer pricing, refers to the process of analysing and comparing financial and economic data from independent companies to establish a fair and arm’s length price for controlled transactions. It is typically conducted using databases that provide details about comparable companies and transactions. The objective is to determine whether the terms and conditions of intercompany transactions... for the related transactions. An example would be a car rental company using the same brand licensing fees charged to third parties as a basis for fees charged to its subsidiaries​.
2. External CUPThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed...: The external CUP methodThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed... compares the controlled transaction with transactions between two independent entities. For example, if a company has no internal comparable transactions, it can look at similar transactions in the market between unrelated parties. A diamond company, for instance, could compare its transactions with those of independent diamond sellers to determine an appropriate transfer priceTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of....

How to Apply the CUP Method

To apply the CUP methodThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed... effectively, follow these steps:

1. Identify the controlled transaction to be analyzed.
2. Find comparable uncontrolled transactions.
3. Determine if adjustments are needed to account for differences.
4. Apply adjustments if necessary.
5. Compare the prices and determine the arm’s length range.

Comparability Factors

When applying the CUP methodThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed..., it’s crucial to consider the following comparability factors:

1. Product characteristics
2. Contractual terms
3. Economic circumstances
4. Business strategies
5. Functional analysisFunctional analysis is the cornerstone of transfer pricing and international tax compliance, ensuring that intercompany transactions adhere to the arm’s length principle. It evaluates the roles, contributions, and risk profiles of entities within a multinational enterprise (MNE) to determine how profits and costs should be allocated. This process ensures that related-party transactions reflect the pricing that independent enterprises would establish... (functions performed, risks assumed, and assets used)

Examples of the CUP Method in Practice

Example 1: Internal CUP Method

Scenario

A company manufactures industrial equipment and sells its products to both unrelated third-party customers and its subsidiaries. Let’s consider that the company produces a specific type of machinery part, the “X500 Gear.”

Internal Comparable Transactions

The company sells the X500 Gear to unrelated third-party distributors at a price of $500 per unit for orders of 1,000 units or more. These transactions are regular and well-documented, providing a clear benchmarkBenchmarking, within the context of transfer pricing, refers to the process of analysing and comparing financial and economic data from independent companies to establish a fair and arm’s length price for controlled transactions. It is typically conducted using databases that provide details about comparable companies and transactions. The objective is to determine whether the terms and conditions of intercompany transactions... for comparison.

Application of Internal CUP

To apply the internal CUP methodThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed..., the company needs to use the $500 per unit price as a benchmarkBenchmarking, within the context of transfer pricing, refers to the process of analysing and comparing financial and economic data from independent companies to establish a fair and arm’s length price for controlled transactions. It is typically conducted using databases that provide details about comparable companies and transactions. The objective is to determine whether the terms and conditions of intercompany transactions... for sales to its subsidiaries. If a subsidiary places an order for 1,000 units, the same price of $500 per unit should be applied. This ensures that the price charged to the subsidiary is at arm’s length, reflecting the market conditions as seen in transactions with unrelated third parties.

Adjustments and Considerations

In this scenario, payment terms, delivery conditions, and volume discounts must be identical or sufficiently adjusted to ensure comparability. For example, if the third-party transactions include a 30-day payment term and free delivery, the same conditions should apply to the subsidiary transactionsIntra-Group Transactions are interactions between entities within the same multinational enterprise (MNE). Such transactions form the backbone of related-party dealings and are essential in managing global operations and aligning business objectives across jurisdictions. Understanding intra-group transactions is critical in international tax and transfer pricing, as they directly impact a company's tax obligations, profitability, and compliance standing. Tax professionals, accountants, lawyers,.... If there are differences, appropriate adjustments must be made to reflect these variances accurately​​.

Example 2: External CUP Method

Scenario

A diamond mining company, “Gemstones Inc.,” sells diamonds to its subsidiary in another country. However, Gemstones Inc. does not have any comparable internal transactionsIntra-Group Transactions are interactions between entities within the same multinational enterprise (MNE). Such transactions form the backbone of related-party dealings and are essential in managing global operations and aligning business objectives across jurisdictions. Understanding intra-group transactions is critical in international tax and transfer pricing, as they directly impact a company's tax obligations, profitability, and compliance standing. Tax professionals, accountants, lawyers,... because it exclusively deals with related entities.

External Comparable Transactions

Gemstones Inc. identifies transactions between independent diamond sellers to determine the transfer priceTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of.... For instance, two independent companies, “Diamond Traders Ltd.” and “Precious Stones Co.,” have recently engaged in similar transactions. Diamond Traders Ltd. sells a particular grade of diamonds at $1,000 per carat to Precious Stones Co. under conditions similar to those between Gemstones Inc. and its subsidiary.

Application of External CUP

Gemstones Inc. uses the $1,000 per carat price from the independent transaction as a benchmarkBenchmarking, within the context of transfer pricing, refers to the process of analysing and comparing financial and economic data from independent companies to establish a fair and arm’s length price for controlled transactions. It is typically conducted using databases that provide details about comparable companies and transactions. The objective is to determine whether the terms and conditions of intercompany transactions... for its sales to the subsidiary. Assuming the diamonds are of comparable quality and quantity and the transaction conditions (e.g., delivery terms, payment period) are similar, this external transaction provides a reliable benchmarkBenchmarking, within the context of transfer pricing, refers to the process of analysing and comparing financial and economic data from independent companies to establish a fair and arm’s length price for controlled transactions. It is typically conducted using databases that provide details about comparable companies and transactions. The objective is to determine whether the terms and conditions of intercompany transactions....

Adjustments and Considerations

If there are any differences, such as the size of the diamond shipments or specific contractual terms, Gemstones Inc. must make adjustments to align these differences. For example, if the independent transaction involves a bulk discount for larger quantities, similar discounts should be considered for the subsidiary if the order size matches​.

Example 3: Internal and External CUP Combination

Scenario

A multinational corporation, AutoTech Ltd., sells a specialized car part, the Turbo X200, to its subsidiaries and unrelated companies. The Turbo X200 is a high-demand product used in various automotive applications.

Internal Comparable Transactions

AutoTech Ltd. sells the Turbo X200 to unrelated third-party customers at $150 per unit for orders exceeding 500 units. These transactions occur frequently and provide a solid basis for comparison.

External Comparable Transactions

Additionally, AutoTech Ltd. reviews market data and finds that similar car parts from competitors, such as “SpeedParts Inc.,” are sold to unrelated parties at $155 per unit under similar conditions.

Application of Combined CUP Method

Using both internal and external comparables, AutoTech Ltd. determines that the appropriate transfer priceTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... for sales to its subsidiary should be within the $150 to $155 per unit range. By analyzing both sets of data, AutoTech Ltd. ensures a robust and defensible transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... strategy.

Adjustments and Considerations

In this combined approach, AutoTech Ltd. must ensure that any differences between the internal and external transactions are accounted for. For instance, if the subsidiary receives a longer credit period than third-party customers, an adjustment must be made to reflect this difference. Similarly, any variations in warranty terms or delivery schedules between internal and external transactions should be adjusted accordingly​.

Advantages of the CUP Method

1. Most direct and reliable method when comparable data is available
2. Preferred by many tax authorities
3. Relatively simple to apply and understand
4. Suitable for commodity transactions with quoted market prices

Limitations and Challenges

1. Difficulty in finding truly comparable uncontrolled transactions
2. Sensitivity to product and transaction differences
3. May require significant adjustments to account for differences
4. Limited applicability for unique or highly specialized products/services

When to Use the CUP Method

The CUP methodThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed... is most appropriate in the following situations:

1. Transactions involving commodities with quoted market prices
2. Simple manufacturing or distribution arrangements
3. Licensing of standard intangible property
4. Intercompany loansIntercompany Loans are financial arrangements where one entity within a corporate group lends funds to another entity in the same group. These loans are common in multinational enterprises (MNEs) and are used to manage liquidity, fund operations, or finance specific projects. The terms and conditions of intercompany loans must adhere to transfer pricing regulations to ensure they reflect arm’s length... and financial transactions

CUP Method and Transfer Pricing Documentation

When using the CUP methodThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed..., it’s essential to maintain robust transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... documentation that includes:

1. Detailed description of the controlled transaction
2. Explanation of the comparability analysisA Comparability Analysis is an essential framework in Transfer Pricing used to evaluate whether the conditions of a transaction between related entities (such as subsidiaries of the same multinational enterprise) are consistent with the arm’s length principle. The arm’s length principle requires that intercompany transactions reflect terms that independent entities would negotiate under comparable circumstances, ensuring that multinational corporations (MNEs)...
3. Information on the selected comparable transactions
4. Details of any adjustments made and their rationale
5. Conclusion on the arm’s length nature of the transaction

The Importance of Professional Guidance

While the CUP methodThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed... can be straightforward in some cases, its application often requires expertise in transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... regulations, economic analysis, and industry-specific knowledge. Consulting with transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... specialists can provide several benefits:

1. Ensuring compliance with local and international transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... regulations
2. Identifying the most appropriate comparable transactions
3. Performing accurate comparability adjustments
4. Developing robust transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... documentation
5. Defending transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... positions in case of tax auditsA Tax Audit is a comprehensive review or examination conducted by a government’s tax authority. The primary objective of a tax audit is to verify the accuracy of a taxpayer's financial records, tax returns, and overall tax compliance. This process ensures that the reported income, expenses, and deductions align with the applicable tax laws and regulations. Tax audits serve as...

In Closing

The Comparable Uncontrolled Price (CUP) methodThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed... is a valuable tool in transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... analysis, offering a direct approach to determining arm’s length prices. However, its effective application requires careful consideration of comparability factors, potential adjustments, and thorough documentation. By understanding the nuances of the CUP methodThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed... and seeking professional guidance when needed, multinational enterprisesWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... can ensure compliance with transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... regulations and mitigate potential tax risksTax Risk refers to the uncertainty surrounding the potential financial or reputational impact of tax-related decisions and events on a business or individual. This risk arises due to various factors, such as complex tax regulations, inconsistent tax authority interpretations, or evolving international tax laws. Effective tax risk management involves identifying, assessing, and mitigating potential tax-related threats to prevent financial penalties,....

References:

1. OECD Transfer Pricing GuidelinesThe OECD Transfer Pricing Guidelines serve as a critical framework for multinational enterprises (MNEs) and tax administrations worldwide. They provide detailed principles for the pricing of intra-group transactions to ensure that profits are allocated fairly across jurisdictions, based on the arm’s length principle. In essence, these Guidelines are instrumental in preventing tax base erosion and profit shifting by MNEs. The... for Multinational EnterprisesWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... and Tax Administrations 2022
   https://www.oecd.org/tax/transfer-pricing/oecd-transfer-pricing-guidelines-for-multinational-enterprises-and-tax-administrations-20769717.htm
2. Internal Revenue ServiceTax authorities are fundamental institutions within government frameworks, overseeing tax assessment, collection, and administration. Their operations ensure that tax laws are enforced and public funds are collected efficiently. This article delves into tax authorities' purpose, responsibilities, and structure, offering insights into their essential role in supporting government functions and economic stability. What is a Tax Authority? A tax authority is... (IRS) – Transfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... Methods
   https://www.irs.gov/businesses/international-businesses/transfer-pricing-methods
3. PwC – Transfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... Perspectives: Comparable Uncontrolled Price methodThe Comparable Uncontrolled Price (CUP) Method is a transfer pricing approach that assesses whether the price charged in an intercompany transaction between related entities is consistent with the arm’s length principle. The arm’s length principle, a fundamental concept in transfer pricing, requires that the conditions of a transaction between associated enterprises be equivalent to those which would have been agreed...
   https://www.pwc.com/gx/en/services/tax/transfer-pricing/comparable-uncontrolled-price-method.html
4. Deloitte – Transfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... Methods
   https://www2.deloitte.com/content/dam/Deloitte/in/Documents/tax/in-tax-transfer-pricing-methods-noexp.pdf
5. EY – Worldwide Transfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... Reference Guide
   https://www.ey.com/en_gl/tax-guides/worldwide-transfer-pricing-reference-guide
6. KPMG – Global Transfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... Review
   https://home.kpmg/xx/en/home/insights/2016/10/global-transfer-pricing-review.html
7. United Nations Practical Manual on Transfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... for Developing Countries
   https://www.un.org/esa/ffd/wp-content/uploads/2017/04/Manual-TP-2017.pdf
8. World Bank Group – Transfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... and Developing Economies: A Handbook for Policy Makers and Practitioners
   https://openknowledge.worldbank.org/handle/10986/25095
9. International Bureau of Fiscal Documentation (IBFD) – Transfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... Database
   https://www.ibfd.org/IBFD-Products/Transfer-Pricing-Database
10. Tax Justice Network – Transfer PricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of...
    https://taxjustice.net/topics/transfer-pricing/