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Once a comparability analysis has been performed which determines the conditions and economically relevant factors of the controlled transaction (see B4.131), these conditions and factors can then be compared with those of comparable transactions of independent enterprises in order to determine an arm's length price. There are various ways to do this depending on the transaction type. The comparable uncontrolled price (CUP) method¹ compares the price charged for property or services in a controlled transaction with the price charged in an uncontrolled transaction. There are two possible types of comparison:

1. Ìý

   •ÌýÌýÌýÌý internal CUP—the price attached to a controlled transaction is compared to the price charged in a comparable transaction between one of the parties to the transaction and an independent enterprise, for example comparing the price a UK company sells goods to a French subsidiary to the price it sells