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Figure Figure 1 Go-to-market & pricing

Which price object is being compared?

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

A schematic mirror chart compares the fields central to a market-facing price object with the fields retained in a transfer-pricing analysis. Relationship, purpose, and terms are shared boundary fields. Functions, assets, risks, comparables, method, and documentation are shown as analysis fields. Values are coded presence indicators, not observed prices.← Market-facing object fieldsTransfer-pricing analysis fields →Object boundaryEvidence field1 coded presence1 coded presenceRelationship named1 coded presence1 coded presenceCommercial purpose1 coded presence1 coded presenceTerms and conditions0 coded presence1 coded presenceFunctions, assets, risks0 coded presence1 coded presenceComparables and method0 coded presence1 coded presenceDocumentation purpose
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Reference & Evidence

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.

Each line is a claim from the register this journal publishes against, resolved from the register at build time.

  • A 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 · OECD22-C1
  • A 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 · OECD22-C2
  • A Functional analysis identifies economically significant activities and responsibilities, assets used or contributed, risks assumed, and what parties actually do OECD (2022), pp. 39-40, 46-47 · official full text · OECD22-C3
  • A Comparability analysis includes understanding the accurately delineated controlled transaction and comparing its conditions with uncontrolled transactions in comparable circumstances United Nations (2021), p. 49 · official full text · UNTP21-C1
  • A Comparability factors include the property or service, contractual terms, functions with assets and risks, economic circumstances, and business strategies United Nations (2021), p. 56 · official full text · UNTP21-C4

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

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