Question Tag: Comparable Uncontrolled Price Method

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AT – May 2020 – L3 – Q2a – Tax administration in Ghana

Explanation of five transfer pricing methods approved by LI 2188 and OECD guidelines.

In July 2012, Ghana introduced new transfer pricing rules and guidelines through Transfer Pricing Regulations, 2012 (LI 2188). The transfer pricing rules require the use of the “most appropriate” method to price related party transactions. Similar to the Organisation for Economic Co-operation and Development (OECD) guidelines, the transfer pricing methods approved by the LI 2188, among others, are:

i) The Comparable Uncontrolled Price method; ii) The Resale Price method; iii) The Cost-Plus method; iv) The Transactional Profit Split method; and the v) Transactional Net Margin Method.

Required: Explain the transfer pricing methods stated above.

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AT – Nov 2023 – L3 – Q1b – Anti-avoidance measures

Explain the Comparable Uncontrolled Price (CUP) method in transfer pricing with an example and state situations for its application

The transfer pricing rules require the use of the “most appropriate” method to price related party transactions. One of such methods is ‘Comparable Uncontrolled Price method’.

Required:
i) Explain with a simple numerical example, the comparable uncontrolled price. (4 marks)
ii) State TWO (2) situations where it is most appropriate to apply the comparable uncontrolled price method. (2 marks)

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AT – May 2020 – L3 – Q2a – Tax administration in Ghana

Explanation of five transfer pricing methods approved by LI 2188 and OECD guidelines.

In July 2012, Ghana introduced new transfer pricing rules and guidelines through Transfer Pricing Regulations, 2012 (LI 2188). The transfer pricing rules require the use of the “most appropriate” method to price related party transactions. Similar to the Organisation for Economic Co-operation and Development (OECD) guidelines, the transfer pricing methods approved by the LI 2188, among others, are:

i) The Comparable Uncontrolled Price method; ii) The Resale Price method; iii) The Cost-Plus method; iv) The Transactional Profit Split method; and the v) Transactional Net Margin Method.

Required: Explain the transfer pricing methods stated above.

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AT – Nov 2023 – L3 – Q1b – Anti-avoidance measures

Explain the Comparable Uncontrolled Price (CUP) method in transfer pricing with an example and state situations for its application

The transfer pricing rules require the use of the “most appropriate” method to price related party transactions. One of such methods is ‘Comparable Uncontrolled Price method’.

Required:
i) Explain with a simple numerical example, the comparable uncontrolled price. (4 marks)
ii) State TWO (2) situations where it is most appropriate to apply the comparable uncontrolled price method. (2 marks)

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