Figure 11 Sept 2026From “Transfer price and market price are different objects”

Which price object is being compared?

Keep the external market observation, the controlled transaction, and the comparison record separate.

Figure 1Which price object is being compared?

Source: Author's schematic presence coding grounded in OECD (2022) and United Nations (2021). A value of 1 means the field is central to the object in this framework; 0 means it is not the primary object. These are not observed prices or company data.

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A OECD22-C1 The arm's-length principle is "the international transfer pricing standard that OECD member countries have agreed should be used for tax purposes by MNE groups and tax administrations"OECD (2022), p. 29 · official full text
A OECD22-C2 The comparison is with what independent parties would have done: Article 9 applies where "conditions are made or imposed between the two enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises"OECD (2022), pp. 31-32 · official full text
A OECD22-C3 Functional analysis identifies economically significant activities and responsibilities, assets used or contributed, risks assumed, and what parties actually doOECD (2022), pp. 39-40, 46-47 · official full text
A UNTP21-C1 Comparability analysis includes understanding the accurately delineated controlled transaction and comparing its conditions with uncontrolled transactions in comparable circumstancesUnited Nations (2021), p. 49 · official full text
A UNTP21-C4 Comparability factors include the property or service, contractual terms, functions with assets and risks, economic circumstances, and business strategiesUnited Nations (2021), p. 56 · official full text

Grades: A, verified against the printed page of the primary source · B, primary source, text layer only · C, authoritative secondary · D, reported.

From the essay

Pricing & revenue architecture

Transfer price and market price are different objects

A market price can inform transfer pricing, but it is not automatically the answer. Start with the transaction, functions, risks and terms.

1 Sept 2026

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APA 7

Isoglu, S. (2026). Which price object is being compared? [Figure]. isoglu.com. https://isoglu.com/insights/exhibits/isoglu-2026-transfer-price-and-market-price-are-different-objects-fig01/

BibTeX

@misc{isoglu-2026-transfer-price-and-market-price-are-different-objects-fig01,
  author = {Isoglu, Sinan},
  title = {{Which price object is being compared?}},
  year = {2026},
  howpublished = {Figure 1, isoglu.com},
  url = {https://isoglu.com/insights/exhibits/isoglu-2026-transfer-price-and-market-price-are-different-objects-fig01/},
  note = {From the essay {Transfer price and market price are different objects}}
}

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<figure>
  <a href="https://isoglu.com/insights/exhibits/isoglu-2026-transfer-price-and-market-price-are-different-objects-fig01/">
    <img src="https://isoglu.com/social/isoglu-2026-transfer-price-and-market-price-are-different-objects-fig01.png" alt="Figure 1: Which price object is being compared?" width="3200" height="2400">
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  <figcaption>Figure 1: Which price object is being compared?. Source: Author&#39;s schematic presence coding grounded in OECD (2022) and United Nations (2021). A value of 1 means the field is central to the object in this framework; 0 means it is not the primary object. These are not observed prices or company data. <a href="https://isoglu.com/insights/exhibits/isoglu-2026-transfer-price-and-market-price-are-different-objects-fig01/">View exhibit</a>.</figcaption>
</figure>