As another example, assume a taxpayer sells 1000 tons of a product for $80 per ton to an associated enterprise in its MNE group, and at the same time sells 500 tons of the same product for $100 per ton to an independent enterprise. This case requires an evaluation of whether the different volumes should result in an adjustment of the transfer price. The relevant market should be researched by analysing transactions in similar products to determine typical volume discounts.
TPG2022 Chapter II paragraph 2.26
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By OECD
Category: OECD Transfer Pricing Guidelines (2022), TPG 2022 Chapter II: Transfer Pricing Methods | Tag: Commodity transaction, Comparable Uncontrolled Price method (CUP), Example - CUP volume discount, Purchase volumes, Traditional transaction methods, Transfer pricing methods, Volume discounts
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