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Comparable uncontrolled price method

The comparable uncontrolled price (CUP) method sets an intercompany transfer price by reference to the price charged in a similar transaction between unrelated parties, adjusted for material differences.

ByHoang TruongUpdated

FrameworkOECD Transfer Pricing Guidelines

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A division sells a connector to an external customer for €25.00 per unit at that customer's usual 200-unit order size. An affiliate orders 1,200 units, which qualifies for the same 12% volume discount any customer ordering over 1,000 units receives. The comparable uncontrolled price method gives €25.00 minus €3.00, an arm's length transfer price of €22.00 per unit.

Where it fits
SubjectManagerial AccountingAdvancedTopicTransfer PricingAdvanced

The formula

LaTeX
PAL=PCUP±ΔP_{AL} = P_{CUP} \pm \Delta

Variables

Arm's length transfer price ()
Comparable uncontrolled price observed in an external transaction ()
Net adjustment for material differences between the internal and external transaction ()

The CUP-based transfer price starts from a real external price and adjusts it for any material difference between the internal and external transaction.