The U.S. IRS allows transfer prices to be set using comparable uncontrolled price method. This method is difficult to apply in practice because many factors enter into the pricing of goods and services. Examples include

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All of the above factors can affect the pricing of goods and services, making it difficult to apply the comparable uncontrolled price method in practice. Differences in the terms of sale, quantity and quality sold, location or date of sale, and other factors must all be carefully considered to arrive at an accurate comparability analysis for transfer pricing purposes.

The US IRS Allows Transfer Prices to Be Set Using Comparable