[Verse 1] When sister companies trade across the globe Setting prices right becomes the goal Tax authorities watch every single deal Market-based methods keep transactions real Independent parties in the open market Show us what the price should truly be Arm's length principle guides our target Fair value for all the world to see [Chorus] CUP and resale, two methods strong Comparable prices where we belong Uncontrolled transactions light the way Market-based pricing saves the day Find the benchmark, match the terms External evidence confirms Transfer pricing done with care Market methods keep it fair [Verse 2] Comparable uncontrolled price comes first External transactions break the thirst For evidence of what third parties pay When similar goods change hands today Product comparability matters most Geographic markets coast to coast Contractual terms must align To make this method truly shine [Chorus] CUP and resale, two methods strong Comparable prices where we belong Uncontrolled transactions light the way Market-based pricing saves the day Find the benchmark, match the terms External evidence confirms Transfer pricing done with care Market methods keep it fair [Verse 3] Resale price method works downstream When distributors fulfill the dream Take the price they sell to customers Subtract their markup, what occurs Is transfer price that should have been If arm's length rules had governed in Functional analysis shows the way What value does each party pay [Bridge] Comparability adjustments fine-tune the deal Economic circumstances must be real Reject the price if differences are large Market-based methods take the charge Documentation proves your case Benchmarking studies set the pace Contemporary data tells the tale Market evidence will never fail [Chorus] CUP and resale, two methods strong Comparable prices where we belong Uncontrolled transactions light the way Market-based pricing saves the day Find the benchmark, match the terms External evidence confirms Transfer pricing done with care Market methods keep it fair [Outro] When related parties need to trade Let market forces guide the grade CPA knowledge leads the way Market-based pricing every day
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