Comparable Uncontrolled Price
Comparable Uncontrolled Price (CUP) is a method used in transfer pricing to determine the price of goods or services between related parties. It compares the price charged in a controlled transaction (between related entities) to the price charged in a similar uncontrolled transaction (between unrelated entities). This helps ensure that the prices set between related parties are consistent with market conditions.
The CUP method is often favored for its simplicity and reliability, as it uses actual market data. To apply this method effectively, it is essential to find comparable transactions that are similar in terms of product, market conditions, and timing.