Applying the Transfer Pricing CUP Method

The arm’s length principle treats the members of a multinational enterprise (MNE) as operating in separate entities, rather than as inseparable parts of a single, unified business. Therefore, it is required that MNEs follow the same pricing policy for intra-group and uncontrolled transactions, under comparable circumstances. Otherwise, the controlled companies shall take the necessary measures and adjust their profits by reference to the conditions, which would have obtained between independent enterprises.Continue Reading