Transfer Pricing: Is the Comparable Uncontrolled Price Method the Best Method in all Cases?

Abstract

The transfer price scope is becoming a very important issue for all companies that comprise from different departments or have a network of branches. These companies are obliged to present the way of price determination for transactions that they have with their branches or other relevant members of their network. The establishment of the multinational companies that develop their activities in various countries is being increased. It has increased the need to supervise their transactions and approval of laws and administrative orders that do not leave space for misuses. The paper is focused in the response to the question if the Comparable Uncontrolled Price Method is the best method to be used in all cases. It is presented through a concrete example that shows how the price of a product determined through the Comparable Uncontrolled Price Method or market price has an impact to the profit of the mother company and other subsidiaries.