Figure 31 Sept 2026From “Transfer price and market price are different objects”

Three records, three decisions

Keep the public observation, the controlled-transaction record, and the comparison decision in separate rows.

Figure 3Three records, three decisions

Source: Author's worksheet grounded in the documentation and comparability boundaries in OECD (2022) and United Nations (2021). Blank fields are reader inputs; no legal or company conclusion is supplied.

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A OECD22-C4 The comparability process moves from transaction understanding and functions to methods, comparables, adjustments, and arm's-length remuneration; reliability matters more than a compulsory processOECD (2022), pp. 150-151 · official full text
A OECD22-C5 The documentation framework separates group-level master-file information, transaction-level local-file information, and aggregate Country-by-Country reportingOECD (2022), pp. 231-233 · official full text
A UNTP21-C3 The practical process includes transaction understanding, comparability factors, methods, comparables, adjustments, documentation, and monitoring, and is not necessarily linearUnited Nations (2021), pp. 52-53 · 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). Three records, three decisions [Figure]. isoglu.com. https://isoglu.com/insights/exhibits/isoglu-2026-transfer-price-and-market-price-are-different-objects-fig03/

BibTeX

@misc{isoglu-2026-transfer-price-and-market-price-are-different-objects-fig03,
  author = {Isoglu, Sinan},
  title = {{Three records, three decisions}},
  year = {2026},
  howpublished = {Figure 3, isoglu.com},
  url = {https://isoglu.com/insights/exhibits/isoglu-2026-transfer-price-and-market-price-are-different-objects-fig03/},
  note = {From the essay {Transfer price and market price are different objects}}
}

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    <img src="https://isoglu.com/social/isoglu-2026-transfer-price-and-market-price-are-different-objects-fig03.png" alt="Figure 3: Three records, three decisions" width="3200" height="2400">
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  <figcaption>Figure 3: Three records, three decisions. Source: Author&#39;s worksheet grounded in the documentation and comparability boundaries in OECD (2022) and United Nations (2021). Blank fields are reader inputs; no legal or company conclusion is supplied. <a href="https://isoglu.com/insights/exhibits/isoglu-2026-transfer-price-and-market-price-are-different-objects-fig03/">View exhibit</a>.</figcaption>
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