Comparable uncontrolled price method. The first of the traditional transaction methods is the CUP and it is based on the market price on comparable goods (Skatteverket, 2010). Market based prices can include both internal and external comparison transactions to ensure that the arm’s length principle is set according to the CUP. Either a comparison can be done with the price used for a similar or the same product that is transferred between two completely independent corporations, an external comparison. Or the price for the same or similar product that is transferred between one of the dependent corporations and one independent corporation can be used, an internal comparison (Eden et al., 2001). To get a meaningful comparison the economically significant features has to be sufficiently comparable to one another. Some examples of these features are terms of the contract, differences in quality and quantity and terms of payment. However, the differences in price can be a symptom of the market situation that prevailed when the agreements were entered into (SKV M 2007:25). According to OECD TP guidelines (1995), assumed that chapter 1, concerning the arm’s length principle, in the same guideline is fulfilled, one of the two following conditions have to be meet in order for a transaction to be comparable.
