[Verse 1] Corporate siblings need a price to trade But family ties can make the numbers fade Independent parties set the market rate Third-party benchmarks seal the transfer's fate When goods flow between your company's doors The taxman wants to see what fair trade scores [Chorus] CUP sets the standard, comparable and clean Uncontrolled transactions paint the pricing scene RPM takes the margin, works it backward true Resale price minus profit, that's the transfer due Market methods matter, arm's length is the key Intercompany dealings done transparently [Verse 2] Comparable Uncontrolled Price takes the lead Find identical products, match the terms you need External benchmarks from the open floor Same conditions, same risk, nothing less or more Database searches reveal the golden mean Independent pricing keeps your records clean [Chorus] CUP sets the standard, comparable and clean Uncontrolled transactions paint the pricing scene RPM takes the margin, works it backward true Resale price minus profit, that's the transfer due Market methods matter, arm's length is the key Intercompany dealings done transparently [Verse 3] Resale Price Method flips the calculation round Start with what the buyer sells, work backward to the ground Gross margin typical for the function served Distribution spreads and markups get preserved Subtract the reasonable profit from retail Transfer price emerges from this backward trail [Bridge] Functional analysis breaks down every role Risk allocation matters for the pricing goal Economic substance over legal form Market-based approaches keep transactions warm [Chorus] CUP sets the standard, comparable and clean Uncontrolled transactions paint the pricing scene RPM takes the margin, works it backward true Resale price minus profit, that's the transfer due Market methods matter, arm's length is the key Intercompany dealings done transparently [Outro] When related parties dance the pricing game Market methods keep the outcomes fair and same Documentation builds your strongest case Transfer pricing done with market's true embrace
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