[Verse 1]
When companies share the same control
Related parties play a different role
Transactions between them need special care
To make sure the pricing is truly fair
Imagine strangers making the same deal
Would they agree to what you reveal?
That's the test we need to apply
Arm's length principle won't lie
[Chorus]
Arm's length, arm's length, that's the golden rule
Comparable Uncontrolled Price is the primary tool
Cost Plus Method when you're marking up
Resale Price when you're selling up
Document, document, everything you do
Transfer pricing methods will see you through
[Verse 2]
Three approaches lead the way today
Traditional methods pave the pathway
When you're selling goods between your firms
CUP method gives the clearest terms
Find external prices for the same
Independent parties in the game
But when comparables are hard to find
Other methods ease your worried mind
[Chorus]
Arm's length, arm's length, that's the golden rule
Comparable Uncontrolled Price is the primary tool
Cost Plus Method when you're marking up
Resale Price when you're selling up
Document, document, everything you do
Transfer pricing methods will see you through
[Verse 3]
Cost Plus works when you're the supplier
Add a margin that won't make you tire
Manufacturing goods for sister company
Mark up costs with reasonable fee
Resale Price flips it all around
When distribution profits must be found
Take the price you sell to outside world
Subtract a margin, watch it unfurl
[Bridge]
Documentation saves you from the pain
Keep your files or face the audit strain
Economic analysis and support
Every decision needs a full report
Functional analysis tells the tale
Who takes risk and who might fail
OECD guidelines light the way
For transfer pricing every day
[Chorus]
Arm's length, arm's length, that's the golden rule
Comparable Uncontrolled Price is the primary tool
Cost Plus Method when you're marking up
Resale Price when you're selling up
Document, document, everything you do
Transfer pricing methods will see you through
[Outro]
Related parties can't just pick a price
Arm's length principle gives advice
CUP, Cost Plus, Resale too
Transfer pricing methods guide you through